Justia Criminal Law Opinion Summaries

In 2016, the defendant was charged with multiple offenses, including possession of a firearm and controlled substances, with enhancements for prior prison terms. The jury found him guilty on most charges, and he later pled guilty to the remaining charge, admitting the prior-prison-term allegations. The trial court imposed but stayed the one-year enhancements for the prior prison terms. In 2022, the California Department of Corrections and Rehabilitation identified the defendant for resentencing under Penal Code section 1172.75, which invalidates certain prior-prison-term enhancements imposed before January 1, 2020.The trial court initially struck the prior-prison-term enhancements but denied a full resentencing hearing, reasoning that the enhancements were not "imposed" within the meaning of section 1172.75 because they were stayed. The Court of Appeal affirmed, interpreting "imposed" to mean "imposed and executed," thus excluding stayed enhancements from the statute's resentencing provisions.The Supreme Court of California reviewed the case and concluded that Penal Code section 1172.75 applies to enhancements that were imposed, regardless of whether they were executed or stayed. The Court held that the statute's language and legislative intent indicate that any enhancement imposed before January 1, 2020, is invalid, and defendants are entitled to resentencing. The Court reversed the Court of Appeal's judgment and remanded the case for further proceedings consistent with this interpretation. View "P. v. Rhodius" on Justia Law

Eric Wiley pled guilty to making a criminal threat in January 2020, for which the trial court imposed a three-year upper term prison sentence, suspended execution, and placed him on probation for three years. In March 2022, while on probation, Wiley pled guilty to being a felon in possession of a firearm. The trial court found he violated his probation terms, revoked probation, and sentenced him to the upper term of three years for the criminal threat and an additional eight months for the firearm possession.The Court of Appeal upheld Wiley’s sentence, rejecting his Sixth Amendment challenge. The court reasoned that the trial court’s findings regarding the increasing seriousness of Wiley’s prior convictions and his poor performance on probation were permissible under the Almendarez-Torres exception, which allows judges to consider recidivism-related facts without a jury.The Supreme Court of California reviewed the case and held that the trial court violated Wiley’s federal constitutional right to a jury trial by adjudicating underlying facts related to his prior convictions and relying on those conclusions to impose an upper term sentence. The court determined that under the recent U.S. Supreme Court decision in Erlinger v. United States, a judge may only determine the fact of a prior conviction and its elements, not make qualitative assessments about the seriousness of prior convictions or probation performance. The court overruled its previous decisions in People v. Towne and People v. Black, which had allowed broader judicial fact-finding related to recidivism.The Supreme Court of California found the error prejudicial and reversed the judgment of the Court of Appeal, remanding the case for further proceedings consistent with its opinion. View "P. v. Wiley" on Justia Law

In 1998, Ruben Gutierrez was charged with capital murder in Texas for his involvement in the killing of Escolastica Harrison. The prosecution argued that Gutierrez used one of two screwdrivers to stab Harrison. The jury convicted him, and he was sentenced to death after the jury found that he either caused Harrison's death, intended to kill her, or anticipated that a human life would be taken. Gutierrez has sought DNA testing of evidence for nearly 15 years, claiming it would prove he was not present at the crime scene. Texas courts denied his requests, stating that even if his DNA was not found, it would not prove his innocence of the underlying crime.Gutierrez filed a federal lawsuit under 42 U.S.C. §1983 against the district attorney, arguing that Texas's DNA testing procedures violated his due process rights. The District Court agreed and granted declaratory relief. However, the Fifth Circuit vacated this judgment, holding that Gutierrez lacked standing because a declaratory judgment would not likely result in the prosecutor allowing DNA testing.The Supreme Court of the United States reviewed the case and held that Gutierrez has standing to bring his §1983 claim. The Court reasoned that a state-created right to postconviction procedures can create rights to other procedures essential to realizing that right. The Court found that a declaratory judgment in Gutierrez's favor would redress his injury by removing the prosecutor's reliance on Article 64 as a reason for denying DNA testing. The judgment of the Fifth Circuit was reversed, and the case was remanded for further proceedings. View "Gutierrez v. Saenz" on Justia Law

In 2009, Tony Hewitt, Corey Duffey, and Jarvis Ross were convicted of multiple counts of bank robbery and conspiracy, along with corresponding §924(c) offenses for using a firearm during a crime of violence. Each received a mandatory 5-year sentence for the first §924(c) count and 25-year mandatory sentences for each additional count, resulting in sentences exceeding 325 years. After successfully challenging some convictions, the Fifth Circuit vacated their sentences, and they were resentenced to between 285 and 305 years. Following the First Step Act of 2018, which reduced mandatory minimum penalties for first-time §924(c) offenders, the District Court vacated more convictions and resentenced them under the pre-Act scheme, resulting in sentences of 130 years or more.The Fifth Circuit denied the joint request by petitioners and the Government to apply the First Step Act’s more lenient penalties, holding that §403(b) applies only to defendants who had not been sentenced as of the Act’s enactment. Since the petitioners had been sentenced twice before the Act, the court concluded they were ineligible for the Act’s benefits.The Supreme Court of the United States reversed the Fifth Circuit’s decision, holding that under §403(b) of the First Step Act, a sentence “has been imposed” only if it remains valid and has not been vacated. Therefore, the Act’s more lenient penalties apply to defendants whose previous §924(c) sentences have been vacated and who need to be resentenced following the Act’s enactment. The case was remanded for further proceedings consistent with this interpretation. View "Hewitt v. United States" on Justia Law

Dwayne Edward Best was convicted of possession of a controlled substance with intent to deliver, trafficking a controlled substance, and unlawful possession of a firearm. Best moved to suppress evidence obtained during a warrantless search of his room, arguing it violated his Fourth Amendment rights. The district court denied the motion, and the case proceeded to a jury trial. Before closing arguments, the State moved to preclude Best from discussing the lack of law enforcement body camera footage for a particular interview, which the district court granted. The jury found Best guilty on all charges, and he filed a timely appeal challenging the district court’s denial of his motion to suppress and its decision limiting his closing argument.The Idaho Court of Appeals affirmed the district court’s decision. Best then filed a petition for review, which the Idaho Supreme Court granted. The Supreme Court reviewed whether Best preserved his suppression arguments for appeal and whether the district court erred by limiting his closing argument. The court held that Best failed to preserve his argument regarding the 2018 Terms and Conditions of Probation because he did not raise it before the district court. Additionally, the court found that Best’s alternative argument about the scope of the search was also not preserved for appeal.The Idaho Supreme Court affirmed the district court’s decision denying Best’s motion to suppress, as the search was permitted by the 2018 Terms and Conditions of Probation. The court also held that the district court erred in precluding Best from discussing the lack of body camera footage during his closing argument but concluded that the error was harmless beyond a reasonable doubt. The court found substantial evidence of Best’s guilt beyond a reasonable doubt, excluding the erroneously precluded closing argument. Consequently, the Idaho Supreme Court affirmed Best’s judgment of conviction. View "State v. Best" on Justia Law

Michael Cobbs pleaded guilty in 2017 to attempted Hobbs Act robbery, using or brandishing a firearm during a crime of violence, and being a felon in possession of a firearm. The attempted Hobbs Act robbery served as the predicate crime of violence for the firearm charge. Cobbs later sought to vacate his 25-year sentence under 28 U.S.C. § 2255, arguing that his § 924(c) conviction was invalid based on the Supreme Court's decision in United States v. Taylor, which held that attempted Hobbs Act robbery is not a crime of violence for purposes of § 924(c).The United States District Court for the Central District of Illinois denied Cobbs’s petition, finding that he had procedurally defaulted his claim by not raising it on direct appeal and that he failed to show cause or actual innocence to excuse the default. The district court also noted that Cobbs admitted to facts supporting a conviction for a completed Hobbs Act robbery, which would still qualify as a crime of violence under § 924(c).The United States Court of Appeals for the Seventh Circuit reviewed the case and affirmed the district court's decision. The appellate court held that Cobbs could not demonstrate actual innocence because he admitted to facts that constituted a completed Hobbs Act robbery, which remains a valid predicate for a § 924(c) conviction. The court concluded that the change in law announced in Taylor did not affect Cobbs’s conviction since his factual admissions supported a completed robbery charge. Therefore, Cobbs’s procedural default was not excused, and his petition to vacate his sentence was properly denied. View "Cobbs v USA" on Justia Law

Richard Hillyer, an inmate at the Pennington County Jail, was convicted of possessing a weapon, specifically an altered razor blade, in violation of SDCL 24-11-47(3). Hillyer had checked out a jail-issued razor, removed the blade, broke it in half, and concealed one half in his mouth while flushing the other half. He claimed he kept the blade to cut himself to relieve anxiety, not to harm others. Jail staff discovered the blade after Hillyer admitted to possessing it and handed it over to Sergeant James Hogue.The Circuit Court of the Seventh Judicial Circuit, Pennington County, South Dakota, presided over Hillyer's trial. The jury found him guilty of the felony charge. Hillyer appealed, arguing that the court erred by rejecting his lesser-included offense instruction, denying his motion for judgment of acquittal due to insufficient evidence, and refusing to instruct the jury not to consider hypothetical uses of the razor blade. He also claimed that the cumulative effect of these errors deprived him of a fair trial.The Supreme Court of the State of South Dakota reviewed the case. The court held that the lesser-included offense instruction was correctly denied because the elements of the lesser offense were not a subset of the greater offense. The court found sufficient evidence to support the jury's verdict, noting that the razor blade could be considered a weapon as defined by law. The court also ruled that the trial court did not abuse its discretion in referring the jury to the existing instructions when they asked about hypothetical uses of the razor blade. The court affirmed the conviction, concluding that Hillyer received a fair trial. View "State v. Hillyer" on Justia Law

Damion L. Butterfield was convicted of murder and other offenses after pleading guilty following a trial but before the jury announced its verdict. He sought to withdraw his guilty plea, arguing that the court abused its discretion by denying his request and his motion for a new trial. Butterfield also appealed his thirty-five-year prison sentence.The trial court (Cumberland County, MG Kennedy, J.) denied Butterfield's motion to withdraw his plea and his motion for a new trial. The court found that Butterfield had multiple opportunities to discuss his options with counsel and that his plea was made voluntarily and with full knowledge of the consequences. The court also noted that Butterfield did not assert his innocence and that the plea was entered after thorough colloquies. The court sentenced Butterfield to thirty-five years in prison, consistent with the joint recommendation of the parties.The Maine Supreme Judicial Court reviewed the case and affirmed the trial court's decision. The court held that the trial court did not abuse its discretion in denying Butterfield's motion to withdraw his plea, as the plea was made voluntarily and with full understanding of the consequences. The court also dismissed Butterfield's appeal of his sentence, noting that discretionary review is unavailable for sentences imposed pursuant to a joint recommendation of the parties. View "State of Maine v. Butterfield" on Justia Law

Raymond Ellis Jr. was convicted of robbery and possession of a firearm by a prohibited person. On August 5, 2023, Ellis, armed with a handgun, and a juvenile accomplice, armed with a sawed-off shotgun, robbed the Big Apple convenience store in Madison. They wore masks, threatened the store clerk, and stole cash from the registers. A third person acted as a lookout. Ellis was sentenced to twenty-five years for robbery, with all but twenty years suspended, and four years of probation, plus a concurrent three-year term for the firearm possession charge.The jury found Ellis guilty of robbery, criminal threatening with a dangerous weapon, and theft by unauthorized taking. The court found him guilty of possession of a firearm by a prohibited person after Ellis waived his right to a jury trial on that count. The court merged the criminal threatening and theft counts with the robbery count for sentencing purposes. Ellis appealed, arguing entitlement to a missing-witness jury instruction and errors in the sentencing process.The Maine Supreme Judicial Court reviewed the case. Ellis contended that the jury should have been instructed to infer that a missing witness would not have corroborated the State’s theory. The court reaffirmed its stance from State v. Brewer, holding that no such inference is permissible. The court also addressed Ellis’s claim of double-counting sentencing factors, noting that the sentencing court improperly considered Ellis’s failure to take responsibility as an aggravating factor. The court vacated Ellis’s sentence and remanded for resentencing, affirming the judgment of conviction in all other respects. View "State of Maine v. Ellis" on Justia Law

Krystle Hoffman was charged with drug-induced homicide after arranging for her roommate to deliver heroin to Lorna Haseltine, who subsequently died from a heroin overdose. Hoffman entered an open guilty plea and sought sentencing under section 5-4-1(c-1.5) of the Unified Code of Corrections, which allows for deviation from mandatory minimum sentences for certain offenses involving drug use or possession. The trial court, however, found that this statute did not apply to drug-induced homicide and sentenced Hoffman to the mandatory minimum six-year prison term.The appellate court vacated Hoffman's sentence, holding that drug-induced homicide involves the possession of drugs and thus falls under section 5-4-1(c-1.5), allowing for a potential deviation from the mandatory minimum sentence. The appellate court remanded the case for a new sentencing hearing.The Supreme Court of Illinois reviewed the case and held that section 5-4-1(c-1.5) does not permit deviation from mandatory minimum sentences for drug-induced homicide. The court reasoned that interpreting the statute to include such offenses would lead to absurd results, as it would allow for leniency in serious crimes involving drug delivery that result in death or other severe consequences. The court concluded that the statute only applies to offenses involving the mere possession of drugs, not those involving additional conduct like delivery.The Supreme Court reversed the appellate court's judgment in part, affirming the trial court's imposition of the mandatory minimum six-year prison term for Hoffman. The case was remanded to the trial court to set the manner and method of paying restitution. View "People v. Hoffman" on Justia Law