Justia Criminal Law Opinion Summaries

A man was convicted by a jury of aggravated sexual abuse of a minor under twelve years of age in Indian Country. The events leading to the charges occurred during his brief marriage to the child’s mother, when he often cared for her seven-year-old daughter while the mother worked night shifts. The child later disclosed the alleged abuse to family members, which was recorded and reported to authorities. During the investigation, law enforcement also received information suggesting the defendant may have abused other young girls, and three additional children testified at trial about similar conduct. The defendant denied all allegations and presented evidence of his good character, medical issues, and the nature of his relationship with the child and her mother.The United States District Court for the Northern District of Oklahoma denied the defendant’s pretrial motion to suppress statements made during a custodial interrogation, finding no coercion or involuntariness. At trial, the court admitted testimony from other alleged victims under Federal Rule of Evidence 414 and allowed certain statements by the defendant’s ex-wife. The court also gave a jury instruction stating that child witnesses are presumed competent and declined to instruct the jury that it must unanimously find, by a preponderance of the evidence, that the defendant committed the other alleged acts before considering them. The jury found the defendant guilty, and he was sentenced to life imprisonment.On appeal, the United States Court of Appeals for the Tenth Circuit reviewed the defendant’s claims of instructional and evidentiary error, the denial of his suppression motion, and the alleged cumulative effect of any errors. The court held that a jury need not unanimously find by a preponderance that a defendant committed Rule 414 acts before individual jurors may consider such evidence. The court found no reversible error in the evidentiary rulings, jury instructions, or suppression decision, and affirmed the conviction. View "United States v. Paycer" on Justia Law

Rajeri Curry was investigated for drug trafficking after purchasing heroin and fentanyl in bulk from two brothers, Al-Tariq and Shadee Brown. Following a fatal overdose linked to drugs Curry sold, police arrested her and seized her iPhone. After being read her Miranda rights, Curry requested a lawyer. Detectives then asked for consent to search her phone, explaining that refusal would lead to a warrant and possible data loss. Concerned about losing her files, Curry provided her passcode and signed a consent form. The detectives did not question her about the charged offenses during this interaction.Curry was indicted in the United States District Court for the District of New Jersey for conspiracy to distribute heroin and fentanyl, possession with intent to distribute, and distribution resulting in death. Before trial, she moved to suppress evidence obtained from her phone, arguing it was inadmissible due to a violation of the Edwards v. Arizona rule. The District Court denied the motion, admitted the evidence, and allowed the prosecution to introduce Curry’s prior drug convictions. After trial, the jury convicted Curry of conspiracy and possession with intent to distribute, but did not reach a verdict on the distribution resulting in death count. The District Court denied Curry’s motion for judgment of acquittal and sentenced her as a career offender to 216 months’ imprisonment.The United States Court of Appeals for the Third Circuit reviewed the case. The court held that evidence derived from Curry’s phone was not subject to suppression under Edwards v. Arizona because Curry voluntarily provided her passcode and consented to the search. The court affirmed the District Court’s judgment, finding no error in the denial of the suppression motion, the sufficiency of evidence for conspiracy, the admission of prior convictions under Rule 404(b), and the application of the career-offender sentencing enhancement. View "USA v. Curry" on Justia Law

A man was arrested after he attempted to meet someone he believed to be a 12-year-old girl for sex, following extensive online and text communications. The “girl” was actually a fictional persona created by law enforcement as part of an undercover operation. After his arrest, officers obtained a warrant to search his residence, where they discovered a large quantity of child pornography on a hard drive. The defendant was charged with attempted coercion and enticement of a minor to engage in illegal sexual activity, as well as possession of child pornography.The United States District Court for the District of Montana denied the defendant’s pretrial motions to suppress the evidence seized from his residence, to sever the two charges in the indictment, and to exclude evidence of his uncharged interactions with a 17-year-old girl. The court found that the search warrant was supported by probable cause, that the charges were properly joined as offenses of similar character, and that the evidence regarding the 17-year-old was admissible to show intent. After a jury convicted the defendant on both counts, the district court sentenced him to 154 months’ imprisonment on each count, to run concurrently.On appeal, the United States Court of Appeals for the Ninth Circuit affirmed the conviction and sentence. The court held that the search warrant was supported by probable cause to search for both enticement and child pornography, and that any omission in the warrant affidavit was immaterial. The court also held that the charges were properly joined under Federal Rule of Criminal Procedure 8(a), and that the evidence of the defendant’s relationship with the 17-year-old was properly admitted under Federal Rules of Evidence 404(b) and 403. Finally, the court found that the sentence was substantively reasonable and did not result in unwarranted sentencing disparity. View "USA V. BOUDREAU" on Justia Law

The defendant was apprehended after driving a vehicle containing nearly 50 pounds of methamphetamine and was convicted of possessing methamphetamine with intent to distribute. In seeking a reduced sentence, he argued that he played only a minor role as a courier in the drug operation, submitting a proffer that identified three other individuals allegedly involved in the scheme. The district court considered the sentencing guidelines, which allow for a downward adjustment if the defendant is a minor participant, but declined to apply the adjustment, finding insufficient evidence to support the claim.Prior to this appeal, the United States District Court for the Eastern District of Oklahoma reviewed the case. The defendant objected to the presentence report’s recommendation against the minor-role adjustment, but did not specifically object to the district court’s explanation for denying the adjustment at sentencing. The district court imposed a sentence of 235 months, at the bottom of the applicable guideline range, without the downward adjustment.On appeal, the United States Court of Appeals for the Tenth Circuit reviewed whether the district court plainly erred in denying the minor-role adjustment and whether the sentence was procedurally or substantively unreasonable. Applying the plain-error standard, the appellate court held that the district court did not err in its explanation or in its consideration of the defendant’s proffer, and that any ambiguity in the district court’s statements should be interpreted in a legally correct manner. The court further held that the sentence was both procedurally and substantively reasonable, as it fell within the guideline range and the district court was not required to explicitly address every statutory factor. The Tenth Circuit affirmed the sentence. View "United States v. Naranjo-Aguilar" on Justia Law

On August 29, 2020, a shooting occurred outside gas stations in DeKalb County, Georgia, resulting in the death of De’Andre Jones. Jedidja Mbungu was identified as the shooter. Witnesses testified that Mbungu and Jones encountered each other in the street, exchanged words, and then Mbungu shot Jones as Jones was running away. No gun was found on or near Jones, and the medical examiner determined that Jones died from a gunshot wound to the back of his head. Mbungu claimed self-defense, testifying that he believed Jones was armed and threatening him, based on prior violent encounters and Jones’s reputation.A DeKalb County grand jury indicted Mbungu for malice murder, felony murder, aggravated assault, and possession of a firearm during the commission of a felony. At trial in October 2023, the jury acquitted Mbungu of malice murder but convicted him of felony murder and the firearm charge. The aggravated assault count merged. The trial court sentenced Mbungu to life in prison plus a suspended five-year sentence for the firearm offense. Mbungu’s motion for a new trial was denied by the trial court in March 2025.The Supreme Court of Georgia reviewed the case. Mbungu argued that the trial court erred by excluding evidence of a prior difficulty with Jones and evidence of Jones’s alleged gang membership, and by refusing to instruct the jury on combat by agreement and mistake of fact. The Supreme Court of Georgia held that any error in excluding the evidence was harmless, as similar evidence was admitted and the self-defense claim was weak. The court also held that the trial court did not err in refusing the requested jury instructions, as the evidence did not support them. The convictions and sentences were affirmed. View "MBUNGU v. THE STATE" on Justia Law

A woman’s body was discovered inside a plastic container on the side of a Georgia interstate in January 2022. The victim was identified as Myra Smith Parlier. The investigation revealed that she died from asphyxia, with evidence indicating she was strangled with a dog leash and suffocated with a trash bag. Items found at her home matched those used in the concealment of her body. Jquantae Jester and his girlfriend, who had been staying at Parlier’s house, were linked to the crime through surveillance footage, use of Parlier’s financial cards, and possession of her belongings. Jester ultimately confessed to killing Parlier after confronting her about a sold shotgun, describing in detail how he strangled and suffocated her, then disposed of her body.A Fulton County grand jury indicted Jester for malice murder, felony murder, aggravated assault, and concealing the death of another. After a mistrial, a second trial resulted in Jester’s acquittal on malice murder but conviction on the remaining charges. The Superior Court of Fulton County sentenced him to life without parole for felony murder and a consecutive ten-year term for concealing the death. Jester’s motion for a new trial was denied, and he appealed to the Supreme Court of Georgia.The Supreme Court of Georgia reviewed several claims, including the admission of other-acts evidence, the lack of a jury instruction on confession corroboration, and alleged discovery violations. The court held that any error in admitting other-acts evidence was harmless due to overwhelming evidence of guilt and proper jury instructions. The omission of a confession corroboration instruction did not amount to plain error because the confession was amply corroborated. The court also found no plain error in admitting expert testimony despite alleged discovery violations. The convictions and sentences were affirmed. View "JESTER v. THE STATE" on Justia Law

On August 6, 2017, the appellant was involved in a fatal shooting after arranging to meet the victim, with whom he had a history of marijuana transactions. The meeting took place at an apartment complex where the appellant was staying. Witnesses observed the appellant acting nervously and possibly carrying a handgun. After the victim arrived, gunshots were heard, and the appellant was seen fleeing with what appeared to be a gun. He returned to the apartment, admitted to shooting someone, and then left the scene without contacting authorities. The victim was found dead with two gunshot wounds, and ballistic evidence linked the shots to a .45-caliber handgun. The appellant, a convicted felon, later testified that he shot the victim in self-defense during an attempted robbery.A Clayton County grand jury indicted the appellant for malice murder, felony murder, aggravated assault, and possession of a firearm by a convicted felon. At trial, the jury found him guilty on all counts. The trial court sentenced him to life without parole for malice murder, with additional consecutive sentences for aggravated assault and firearm possession. The felony murder counts were vacated by operation of law, and one aggravated assault count merged with the malice murder conviction. The appellant filed a motion for a new trial, which was initially granted but then vacated; the motion was ultimately denied. The case was transferred from the Court of Appeals to the Supreme Court of Georgia.The Supreme Court of Georgia held that the appellant’s trial counsel did not render ineffective assistance by failing to stipulate to his felon status or by eliciting testimony about his juvenile history, as these were either not deficient or were reasonable strategic decisions. However, the Court found a merger error regarding the aggravated assault conviction for the non-fatal shot and vacated that conviction and sentence. The remainder of the judgment was affirmed. View "FRASER v. THE STATE" on Justia Law

The case concerns an individual who was indicted for multiple offenses, including malice murder, felony murder predicated on aggravated assault, and related firearm charges, following the shooting death of a man in Clayton County, Georgia. The incident occurred after a confrontation in a motel parking lot, where witnesses reported that the defendant instructed a co-indictee to shoot the victim, resulting in the victim’s death nearly a year later from complications related to the gunshot wounds. The defendant initially pleaded not guilty but later entered a negotiated guilty plea to felony murder.The Superior Court of Clayton County accepted the guilty plea after a hearing in which the defendant completed a detailed waiver form and participated in a colloquy with the judge to confirm his understanding of his rights, including the right to withdraw his plea before sentencing. The court merged certain charges for sentencing, vacated others by operation of law, and sentenced the defendant to life in prison with the possibility of parole. The defendant did not attempt to withdraw his plea before or after sentencing but appealed, arguing that the trial court erred by accepting his plea without a sufficient factual basis and by requiring him to waive his right to withdraw the plea prior to sentencing.The Supreme Court of Georgia reviewed the appeal and held that the trial court satisfied the requirement to establish a factual basis for the plea, as the prosecutor’s proffered facts were sufficient to support the felony murder charge. The Court further held that the statutory right to withdraw a guilty plea before sentencing is waivable if the waiver is made knowingly, voluntarily, and intelligently, and found that the record demonstrated a valid waiver in this case. The Supreme Court of Georgia affirmed the conviction and sentence. View "PRIEST v. THE STATE" on Justia Law

The case concerns the conviction of a man for the malice murder of his wife, who was found beaten and stabbed to death in their Georgia home. The victim’s mother and son, after being unable to reach her, traveled from Chicago to Georgia and, with police assistance, eventually discovered her body concealed under a pile of clothes. The investigation revealed a history of controlling and violent behavior by the defendant toward the victim, evidence of his flight from Georgia to Chicago in the victim’s car, and his subsequent armed standoff with police in Chicago, during which he threatened suicide and possessed knives matching those found at the crime scene.A Henry County grand jury indicted the defendant for malice murder, felony murder, and aggravated assault. After a jury trial in the Superior Court of Henry County, he was found guilty on all counts and sentenced to life without parole. The defendant filed a motion for new trial, which was denied after an evidentiary hearing. He then appealed to the Supreme Court of Georgia.The Supreme Court of Georgia affirmed the convictions and sentence. The court held that trial counsel was not constitutionally ineffective for failing to request a specific jury instruction on impeachment by bias, as the instructions given sufficiently covered the concept. The court also found no plain error in the admission of certain forensic testimony and reports, concluding that any potential Confrontation Clause violation did not affect the outcome given the overwhelming evidence of guilt. The admission of evidence regarding knives found in the defendant’s possession was deemed intrinsic to the case and not unfairly prejudicial. Finally, the court rejected the claim of cumulative error, finding no denial of a fundamentally fair trial. View "FELTON v. THE STATE" on Justia Law

Two individuals, India Royal and Cameron Woods, were found shot to death in their car in a Walmart parking lot in Riverdale, Georgia, on January 13, 2017. The investigation revealed that both victims were killed by 9mm bullets while seated in their vehicle, which contained evidence of drug distribution. Surveillance footage showed a distinctive white Mercury Mountaineer circling the parking lot before the shooting, and a tall man was seen exiting the Mountaineer, entering the victims’ car, and then leaving shortly before the Mountaineer drove away. The vehicle was registered to the appellant’s mother, who confirmed that her son, Deanthony Ealey, had possession of it that day. Cell phone records linked communications between Woods and a number associated with Ealey around the time of the murders. Ealey was later identified as the person driving the Mountaineer at a nearby ATM after the murders.The Superior Court of Clayton County tried Ealey on two counts of malice murder, two counts of felony murder, and two counts of aggravated assault. The jury found him guilty on all counts, and he was sentenced to consecutive life terms without parole. Ealey filed a motion for a new trial, which was denied after evidentiary hearings.The Supreme Court of Georgia reviewed Ealey’s appeal, in which he argued that the evidence was insufficient, that the trial court erred in admitting other-acts and hearsay evidence, that his counsel was ineffective, and that cumulative errors warranted reversal. The court held that the evidence was sufficient to support the convictions under both constitutional and Georgia statutory standards, that any errors in admitting other-acts or hearsay evidence were harmless, and that Ealey failed to show ineffective assistance or cumulative error. The Supreme Court of Georgia affirmed Ealey’s convictions and sentences. View "EALEY v. THE STATE" on Justia Law