Justia Criminal Law Opinion Summaries

In 2007, an individual was confronted by a store employee outside a Walmart in Hot Springs regarding stolen merchandise. The individual responded by brandishing a firearm. A jury in Garland County found him guilty of aggravated robbery, and he was sentenced to thirty years in prison. The Arkansas Court of Appeals later affirmed both his conviction and sentence.The individual subsequently filed a petition for writ of habeas corpus in the Chicot County Circuit Court, along with a request to proceed in forma pauperis. He argued that the criminal information in his case was not properly file-marked or accompanied by the required cover sheet, allegedly depriving the trial court of jurisdiction. The circuit court found that he had previously raised identical claims in an earlier petition and denied his request to proceed in forma pauperis, concluding that he failed to state a claim for which relief could be granted.The Supreme Court of Arkansas reviewed the circuit court’s denial of pauper status for abuse of discretion. The court held that the petitioner’s arguments regarding the lack of a file-mark and cover sheet did not implicate the facial validity of the judgment or the jurisdiction of the trial court, but rather amounted to claims of trial error. The court further found that the circuit court had subject-matter jurisdiction over the criminal case and that the petitioner failed to state a colorable cause of action for habeas relief. Accordingly, the Supreme Court of Arkansas affirmed the circuit court’s denial of the petition to proceed in forma pauperis. View "CARTER v. PAYNE" on Justia Law

A man was arrested after being found in Oregon with a seventeen-year-old girl who had been reported missing in Utah. Prior to her disappearance, the girl had exchanged numerous messages with the man and discussed plans to be together. After their apprehension, the girl gave statements in both Oregon and Utah, initially indicating that she had lied about her age but later stating that the man knew she was seventeen and had coerced her into leaving and engaging in sexual acts. Based on her statements, the State of Utah charged the man with multiple felonies, including aggravated kidnapping and sexual offenses. A magistrate issued a no-bail warrant, and the district court later denied the man’s motion for pretrial release, finding substantial evidence for the charges and determining he posed a danger and flight risk.The First District Court in Logan, Utah, initially denied the defendant’s motion for pretrial release, and he did not appeal that decision. Several months later, he filed a motion to modify the pretrial detention order, arguing that new DNA evidence constituted a material change in circumstances. The district court denied this motion, finding no material change, and the defendant then filed a direct appeal from this denial.The Supreme Court of the State of Utah reviewed whether it had jurisdiction to hear an immediate appeal from the denial of a motion to modify a pretrial detention order. The court held that under Utah Code § 77-20-209, a defendant has a right to an immediate, expedited appeal only from a pretrial status order that initially orders detention, not from a denial of a motion to modify such an order. Because the defendant did not appeal the original detention order and did not seek interlocutory review of the denial of his motion to modify, the court concluded it lacked jurisdiction and dismissed the appeal. View "State v. Harris" on Justia Law

A state trooper stopped a vehicle for speeding in Waller County, Texas. The driver and passenger appeared nervous, and the trooper noticed strong odors of food and cigarillo smoke, with a possible faint smell of marijuana. After the occupants denied consent to search, a backup officer arrived with a drug-detection dog. During an open-air sniff, the dog’s handler directed the dog to various parts of the vehicle. The dog repeatedly jumped up and stuck its nose through the open passenger window into the car’s interior. After the third intrusion, the dog alerted, and officers searched the vehicle, finding a large quantity of pills. The driver was charged with possession of a controlled substance.The 506th District Court of Waller County initially denied the defendant’s motion to suppress, finding that the totality of the circumstances provided reasonable suspicion and that the dog’s alert provided probable cause. Upon reconsideration, however, the trial court granted the motion to suppress, concluding that the dog’s nose entering the vehicle constituted a trespass and an unlawful search under the Fourth Amendment, and that the evidence found should be excluded. The Fourteenth Court of Appeals affirmed, holding that the dog’s intrusion into the vehicle’s interior was an unreasonable search.The Texas Court of Criminal Appeals reviewed the case and affirmed the court of appeals’ decision. The court held that the repeated physical intrusion of the drug-detection dog’s nose into the interior of the vehicle during an open-air sniff constituted a search under the Fourth Amendment. Because this search was conducted without probable cause, the trial court properly suppressed the evidence obtained as a result. The court clarified that such an intrusion is distinct from a routine exterior sniff and is subject to constitutional protections. View "STATE OF TEXAS v. ORGAN" on Justia Law

The case concerns an individual who was stopped by a Harris County Sheriff’s Deputy for a traffic violation. The individual, who was a convicted felon with an active warrant for a parole violation, was driving a car borrowed from his sister and was armed with her handgun. During the stop, the individual lied about his identity and, after his passenger left the scene, shot and killed the deputy at close range while the deputy was standing by his patrol car. The individual fled, disposed of the weapon, and was later apprehended at a nearby shopping center. At trial, he admitted to the shooting but claimed it was accidental, asserting he was attempting a citizen’s arrest.The 230th Judicial District Court of Harris County tried the case. The jury found the individual guilty of capital murder and, after considering evidence of his extensive criminal history and lack of remorse, answered the special issues in a manner that resulted in a death sentence. The individual represented himself at trial after waiving his right to counsel, but later unsuccessfully sought to withdraw that waiver and have counsel reappointed. He raised several points of error on appeal, including challenges to the sufficiency of the evidence, the denial of his request to withdraw his waiver of counsel, the admission of certain punishment-phase evidence, and the constitutionality of Texas’s death penalty statute.The Texas Court of Criminal Appeals reviewed the case on direct appeal. The court held that the evidence was legally sufficient to support both the conviction for capital murder and the jury’s finding of future dangerousness. It found no abuse of discretion in the trial court’s denial of the request to withdraw the waiver of counsel, nor in the admission of the challenged evidence. The court also determined that the constitutional challenges to the death penalty statute were not preserved for review and, in any event, lacked merit. The conviction and sentence of death were affirmed. View "SOLIS v. STATE OF TEXAS" on Justia Law

The case concerns a defendant who, after a contentious visit to San Antonio Police Department headquarters regarding a child custody issue, returned later that day and fatally shot a police detective who was sitting in his patrol car. The defendant was apprehended the following day by a SWAT team, and during and after his arrest, he made several incriminating statements to law enforcement, a detention officer, and a mental health assessor. At trial, the defendant challenged the admissibility of these statements, arguing they were involuntary or obtained in violation of his rights. He also raised issues regarding jury selection, the presence of alternate jurors during deliberations, and the constitutionality of certain aspects of Texas’s capital sentencing scheme.The 379th District Court of Bexar County conducted the trial. The jury convicted the defendant of capital murder for killing a peace officer in the line of duty and, based on their answers to special sentencing issues, imposed a sentence of death. The defendant raised multiple points of error on direct appeal, including claims that his statements should have been suppressed, that the State’s peremptory strike of a Black venireperson was racially motivated, that the presence of alternate jurors during deliberations violated statutory and constitutional rights, and that the Texas capital sentencing statute is unconstitutional.The Texas Court of Criminal Appeals reviewed the case on automatic direct appeal. The court held that the trial court did not err in admitting the defendant’s statements, as they were either voluntary or not the product of custodial interrogation. The court found no clear error in the trial court’s rejection of the Batson challenge, concluding the State’s reasons for the peremptory strike were race-neutral. The court determined that the presence of alternates during deliberations, while a statutory violation, was harmless error. The court also rejected the constitutional challenges to the sentencing scheme. The conviction and death sentence were affirmed. View "MCKANE v. STATE OF TEXAS" on Justia Law

Andrew Johnston was convicted by a jury of attempted bank robbery and sentenced to 168 months in prison. While awaiting transfer to federal prison, Johnston reported to authorities that a fellow inmate, a Sinaloa Cartel leader, had ordered a hit on another inmate. Johnston assisted law enforcement by recording a conversation with the cartel leader and later testified at the cartel leader’s sentencing hearing. Although the judge in that case did not credit Johnston’s testimony, the recorded conversation was considered in sentencing the cartel leader. In recognition of Johnston’s assistance, the government moved for a 25% reduction in his sentence under Rule 35(b) of the Federal Rules of Criminal Procedure, but the motion was filed more than two years after Johnston’s sentencing.The United States District Court for the Northern District of Illinois, Eastern Division, addressed the government’s untimely Rule 35(b) motion, accepting the government’s waiver of the one-year time limit. The judge found Johnston’s cooperation useful but determined that his repeated frivolous postconviction litigation undermined any inference of genuine acceptance of responsibility. As a result, the court granted only a 10% reduction, lowering Johnston’s sentence to 151 months, rather than the 25% requested.On appeal, the United States Court of Appeals for the Seventh Circuit first considered whether the district court had jurisdiction to entertain the untimely Rule 35(b) motion. The Seventh Circuit held that the one-year time limit in Rule 35(b)(1) is a nonjurisdictional claim-processing rule, which may be waived, overruling its prior decision in United States v. McDowell. The court further held that no legal rule barred the district judge from considering Johnston’s postconviction litigation conduct in evaluating his acceptance of responsibility. The court affirmed the district court’s decision to grant only a 10% sentence reduction. View "USA v Johnston" on Justia Law

Casa Express Corp. obtained a $40 million judgment in the Southern District of New York against the Bolivarian Republic of Venezuela for unpaid bonds and a global note. After Venezuela failed to pay, Casa sought to enforce the judgment in Florida by targeting eight Miami properties owned by corporate entities allegedly controlled by Raul Gorrin Belisario. Casa claimed that Gorrin, through a bribery and currency-exchange scheme involving Venezuelan officials, used misappropriated Venezuelan funds to purchase these properties, and argued that the properties should be subject to a constructive trust in favor of Venezuela.Casa registered the New York judgment in the United States District Court for the Southern District of Florida and initiated supplementary proceedings under Florida law, seeking to execute the judgment against the properties. Casa impleaded Gorrin, several individuals, and six corporate entities as third-party defendants. The defendants moved for judgment on the pleadings, arguing, among other things, that the district court lacked ancillary jurisdiction over Casa’s claims. The magistrate judge recommended dismissal for lack of ancillary jurisdiction, and the district court adopted this recommendation, also finding a lack of personal jurisdiction over Gorrin. Casa appealed.The United States Court of Appeals for the Eleventh Circuit held that the district court lacked ancillary jurisdiction over Casa’s supplementary proceedings. The court reasoned that Casa’s action sought to impose liability on third parties not previously found liable for the New York judgment and was based on new facts and legal theories unrelated to the original breach of contract claims against Venezuela. The Eleventh Circuit affirmed the district court’s jurisdictional ruling, vacated its alternative merits rulings, and remanded with instructions to dismiss the case without prejudice for lack of subject matter jurisdiction. View "Casa Express Corp v. Bolivarian Republic of Venezuela" on Justia Law

Over several months, the defendant participated in four carjackings targeting Lyft drivers in Detroit. In each incident, two assailants, including the defendant, brandished firearms, demanded money and property, and forced the victims to remove their clothing before fleeing in the stolen vehicles. One victim was pistol-whipped and sustained bodily injury. Extensive evidence, including phone records, cell site data, and identification by a victim, linked the defendant to each carjacking. A search of his residence uncovered multiple firearms and stolen vehicles. The defendant pleaded guilty to four counts of carjacking, aiding and abetting, admitting involvement but attempting to minimize his role in some attacks.The United States District Court for the Eastern District of Michigan prepared a presentence report recommending several offense level enhancements under the Sentencing Guidelines, including increases for brandishing and using firearms and for causing bodily injury. The defendant objected, arguing for a mitigating role reduction based on his claimed minor participation. The district court rejected his arguments, found by a preponderance of the evidence that he was a principal in each carjacking, and applied all recommended enhancements. The court imposed an above-Guidelines sentence of 180 months, citing the severity and humiliating nature of the crimes, the defendant’s prior criminal history, and his lack of respect for the law.On appeal, the United States Court of Appeals for the Sixth Circuit reviewed the procedural and substantive reasonableness of the sentence. The court held that the district court did not clearly err in its factual findings or in applying the offense level enhancements, nor did it plainly err in denying a mitigating role reduction or in considering the defendant’s age and rehabilitation potential. The appellate court found the upward variance substantively reasonable, given the egregious nature of the offenses and the impact on the victims. The sentence was affirmed. View "United States v. Haile" on Justia Law

In this case, police in Denver were investigating a shooting that occurred early in the morning. They identified a suspect described as a light-skinned Black male with a bald head, thick beard, and muscular build, and circulated a photo of him. Later that day, officers surveilled a vehicle believed to be connected to the suspect. When a group, including a Black male with some similar clothing but not matching the suspect’s physical description, arrived in a different car and then left in a third vehicle, officers decided to stop that vehicle at a gas station. During the stop, officers detained Noah Huerta, a passenger, and conducted a patdown, finding a firearm magazine on him. A subsequent search of the vehicle, after obtaining the driver’s consent, revealed a handgun near Huerta’s seat.The United States District Court for the District of Colorado denied Huerta’s motion to suppress the evidence, finding that the officers had reasonable suspicion to believe he was armed and dangerous, and also ruled that the firearm would have been inevitably discovered. The court also denied Huerta’s motion to dismiss the indictment, which challenged the constitutionality of the felon-in-possession statute under recent Supreme Court precedent.On appeal, the United States Court of Appeals for the Tenth Circuit reviewed the denial of the motion to suppress de novo. The court held that the officers lacked reasonable suspicion to believe Huerta was armed and dangerous, as the connection between the group and the shooting suspect was tenuous and based on a mere hunch, and the conduct of the vehicle’s occupants was innocuous. The court also found that the inevitable discovery doctrine did not apply. However, the Tenth Circuit affirmed the district court’s denial of the motion to dismiss the indictment, as binding circuit precedent foreclosed Huerta’s constitutional challenge. The court reversed the denial of the motion to suppress and remanded for further proceedings. View "United States v. Huerta" on Justia Law

Darrell Sanders was arrested after two separate incidents in Kirkwood, Missouri, where he approached two minor girls, C.B. and P.H., near an elementary school. Sanders circled the school in his minivan, asked C.B. to see her feet, and invited P.H. to his van, making a suggestive statement. Upon arrest, Sanders admitted to having sexual thoughts about children, acknowledged his interactions with the girls made him feel excited and scared, and confessed to possessing and viewing child pornography on the same day as the incidents. A search of his devices revealed multiple images and videos of child pornography.The United States District Court for the Eastern District of Missouri accepted Sanders’s guilty plea to receipt and possession of child pornography. At sentencing, the court applied a five-level increase under the United States Sentencing Guidelines for engaging in a pattern of activity involving the sexual abuse or exploitation of a minor, based on Sanders’s conduct with C.B. and P.H. The court determined an advisory guideline range of 121 to 151 months and sentenced Sanders to 132 months’ imprisonment. Sanders objected to the application of the enhancement and to certain factual statements in the presentence report, but the district court overruled his objections.The United States Court of Appeals for the Eighth Circuit reviewed the district court’s factual findings for clear error and its application of the guidelines de novo. The appellate court held that the district court did not clearly err in finding that Sanders’s conduct constituted attempted enticement of a minor under Missouri law, supporting the five-level enhancement. The court also found that any factual error in the presentence report was harmless and did not affect the outcome. The Eighth Circuit affirmed the judgment and sentence imposed by the district court. View "United States v. Sanders" on Justia Law