Justia Criminal Law Opinion Summaries

The case involves Stephanie Vance, who was convicted of first-degree murder after the shooting death of her husband, Christopher Bland, in their Philadelphia, Mississippi residence. Bland called 911 stating he had been shot, and when officers arrived, they found him unresponsive with a gunshot wound to the chest. Vance claimed the shooting was accidental, occurring when Bland grabbed her arm as she was leaving with her gun to go to a women’s shelter. Physical evidence included gunshot residue on Vance’s hands and conflicting accounts about whether the gun was holstered. The autopsy showed no evidence of close-range discharge.The Neshoba County Circuit Court presided over the jury trial and found Vance guilty of first-degree murder. Vance appealed, arguing that the trial court erred in allowing a culpable-negligence-manslaughter instruction, excluding lay-opinion testimony about abuse, and that the evidence was insufficient for a murder conviction. She also asserted ineffective assistance of counsel for failure to introduce video evidence.The Supreme Court of Mississippi reviewed the case. It found that Vance was procedurally barred from challenging the manslaughter instruction due to lack of objection at trial, and the instruction was warranted based on the evidence. The exclusion of the lay-opinion testimony was affirmed, as the witness lacked first-hand knowledge of the events at the time of the shooting. The Court determined that the evidence was sufficient for the jury to conclude deliberate design, and the verdict was not against the overwhelming weight of evidence. The ineffective assistance claim regarding the video was dismissed without prejudice due to insufficient record. The Supreme Court of Mississippi affirmed the conviction for first-degree murder. View "Vance v. State of Mississippi" on Justia Law

The defendant was charged with possessing a firearm after having been convicted of felonies, including drug trafficking and DUI. At the time he allegedly possessed the firearm, he was on supervised release for the DUI offense. He was indicted under 18 U.S.C. § 922(g)(1), which prohibits firearm possession by felons. The defendant moved to dismiss the indictment, arguing that § 922(g)(1) was unconstitutional on multiple grounds. After the district court denied his motion, he pleaded guilty while preserving his right to appeal the constitutional issues.The United States District Court for the Southern District of Mississippi denied the defendant’s motion to dismiss the indictment, rejecting his constitutional challenges to § 922(g)(1). Following his guilty plea, the defendant appealed, raising several arguments: that the statute was unconstitutional under the Second Amendment (both facially and as applied), violated Equal Protection, exceeded Congress’s authority under the Commerce Clause, and was unconstitutionally vague. The court noted that Fifth Circuit precedent foreclosed all arguments except the vagueness challenge.The United States Court of Appeals for the Fifth Circuit reviewed the preserved vagueness challenge de novo. The court held that § 922(g)(1) is not void for vagueness, emphasizing that the statute clearly defines the prohibited conduct—possession of a firearm by a felon. The court further held that recent developments in Second Amendment jurisprudence, including New York State Rifle & Pistol Association v. Bruen and United States v. Diaz, did not render the statute vague in the defendant’s case, as these precedents did not affect the clarity of the statutory language or create confusion for ordinary persons. Accordingly, the Fifth Circuit affirmed the conviction. View "United States v. Landrum" on Justia Law

The case concerns a defendant who was charged with multiple counts of attempted murder and assault with a deadly weapon after allegedly committing a series of violent, racially motivated attacks using a metal pipe. The defendant, who has a documented history of serious mental illness, substance abuse, and noncompliance with treatment, moved for pretrial mental health diversion under Penal Code section 1001.36. The motion was supported by a psychological report indicating that the defendant’s mental disorder was treatable and played a significant role in the offenses, but the expert’s opinion that the defendant would not pose an unreasonable risk to public safety was conditioned on his compliance with treatment.The Superior Court of Los Angeles County granted the motion for diversion, ordering the defendant into a community-based mental health program with regular medication, monitoring, and court oversight. The People, represented by the district attorney, opposed the diversion and subsequently petitioned the California Court of Appeal for a writ of mandate. They argued that no evidence demonstrated the defendant would actually comply with treatment if released into the community, and thus, there was insufficient support for the trial court’s implied finding that he would not pose an unreasonable risk of danger.The California Court of Appeal, Second Appellate District, Division One, reviewed the record and found that there was no express or substantial evidence supporting the trial court's implicit determination that the defendant would not pose an unreasonable risk to public safety if treated in the community. The appellate court held that, where there is a history of noncompliance with treatment and no evidence of likely future compliance, a court abuses its discretion in granting diversion. Accordingly, the appellate court issued a peremptory writ of mandate directing the superior court to vacate its order granting mental health diversion and to enter a new order denying the motion. View "People v. Superior Court" on Justia Law

Police officers in Rock Island, Illinois, attempted to stop an unregistered minivan driven by Atoris Slater in July 2020. Slater fled, leading officers on a high-speed chase that ended when they discontinued pursuit after he nearly caused a collision. Slater abandoned the minivan and tried to hide in a dumpster but was found shortly after. Police searched the vehicle and discovered a loaded handgun, marijuana, and cannabis edibles. Upon his arrest and transport to jail, Slater attempted to discard a bag containing crack cocaine. He was indicted for possession of controlled substances with intent to distribute, possession of a firearm as a felon, and possession of a firearm in furtherance of a drug-trafficking crime.The United States District Court for the Central District of Illinois handled the case. Slater pleaded guilty to all counts without a plea agreement, and the presentence report (PSR) initially calculated his sentencing range using a 1:1 drug-conversion ratio for marijuana and cannabis edibles. The government did not object to the PSR within the standard 14-day period. On the eve of sentencing, the prosecutor learned that the edibles contained THC, which required a higher 1:167 conversion ratio, and raised a late objection. The judge granted a continuance, allowed for lab testing, and ultimately adopted the new calculations, resulting in a higher sentencing range. Slater did not renew his objection to the revised PSR and was sentenced below the revised Guidelines range.On appeal, the United States Court of Appeals for the Seventh Circuit reviewed whether the district judge properly allowed the government’s untimely objection to the PSR and whether the higher THC conversion ratio applied. The Seventh Circuit held that the district judge did not abuse her discretion by permitting the late objection for good cause. The court also found that Slater had waived any challenge to the THC ratio by affirmatively accepting the revised PSR at sentencing. The judgment was affirmed. View "United States v. Slater" on Justia Law

A noncitizen and lawful permanent resident was arrested in Virginia after participating in a cocaine transaction observed and recorded by law enforcement. He was indicted for conspiracy to distribute cocaine and possession with intent to distribute. Through retained counsel, he negotiated a plea agreement in which he pleaded guilty to the conspiracy charge, avoiding a mandatory minimum sentence, while the government dropped the other charge. The final agreement omitted certain adverse immigration provisions, but included an acknowledgment that he wished to plead guilty regardless of immigration consequences, including potential automatic removal.After sentencing, the defendant learned he would be subject to mandatory deportation. He filed a motion under 28 U.S.C. § 2255 in the United States District Court for the Eastern District of Virginia, claiming his attorney provided ineffective assistance by failing to advise him that his guilty plea would result in mandatory deportation. The district court initially denied relief, finding he had not shown prejudice, relying on his plea agreement’s language. On appeal, the United States Court of Appeals for the Fourth Circuit held that he had demonstrated prejudice and remanded for the district court to consider whether counsel’s performance was constitutionally deficient.On remand, following an evidentiary hearing, the district court found the attorney had advised the defendant he was “deportable” and would face deportation proceedings, but did not state he would definitely be deported or was subject to “mandatory deportation.” The court held that, given the complexities and uncertainties of immigration outcomes, counsel’s advice met constitutional standards.The United States Court of Appeals for the Fourth Circuit affirmed. The court held that, when the clear consequence of a plea is deportability, counsel need only advise that the plea will render the defendant deportable and subject to removal proceedings; there is no constitutional requirement for counsel to state that deportation is mandatory or absolutely certain. View "United States v. Murillo" on Justia Law

Between December 2007 and February 2008, the defendant and accomplices robbed seven Florida convenience stores and attempted to rob two others, occasionally stealing cash and cigarettes. In April 2009, a federal grand jury indicted him on twenty-two counts related to conspiracy, robbery, attempted robbery, and using or brandishing a firearm during crimes of violence. A jury convicted him on eighteen counts, and the United States District Court for the Southern District of Florida sentenced him to 196 years in prison, primarily due to consecutive mandatory minimum sentences under 18 U.S.C. § 924(c).After the Supreme Court’s decisions in Johnson v. United States, United States v. Davis, and United States v. Taylor clarified the definition of “crime of violence” under § 924(c), the defendant filed petitions under 28 U.S.C. § 2255. The Eleventh Circuit permitted a limited successive motion challenging only his § 924(c) conviction predicated on attempted Hobbs Act robbery (Count Sixteen). The district court vacated that count and held a de novo resentencing, ultimately imposing a new 173-year sentence. The defendant argued for application of the more lenient sentencing provisions of the First Step Act of 2018 (“FSA”) and sought to challenge his other § 924(c) convictions, but the district court declined both requests. On appeal, the Eleventh Circuit originally affirmed.After the Supreme Court decided Hewitt v. United States, which held that defendants resentenced after the FSA’s enactment are eligible for its revised penalties, the Eleventh Circuit granted rehearing. The United States Court of Appeals for the Eleventh Circuit held that the FSA applies retroactively to the defendant’s resentencing and vacated his sentence, remanding for resentencing under the FSA. The court affirmed that the district court lacked jurisdiction to consider new challenges to other counts not authorized by the appellate court. View "United States v. Ragland" on Justia Law

The case concerns an individual who was convicted by a jury of first-degree murder with the use of a deadly weapon and burglary while in possession of a deadly weapon, following the fatal stabbing of his former girlfriend. The incident occurred after the defendant, who was intoxicated, engaged in a confrontation with the victim and her husband at their residence. The defendant admitted to stabbing the victim, and the victim died from her wounds. Law enforcement apprehended the defendant shortly after the incident.The Eighth Judicial District Court in Clark County presided over the trial. During jury selection, the defendant raised a Batson challenge, arguing that the State used peremptory strikes in a racially discriminatory manner. The district court denied the challenge at step one, finding insufficient evidence to raise an inference of discrimination. The defense also moved to exclude testimony from a substitute coroner, challenged the admission of a transcript of a 911 call, and disputed limitations placed on their expert's testimony about intoxication. The district court allowed the substitute coroner to testify to her own opinions based on photographs and hospital records, permitted the jury to use the 911 call transcript as a listening aid, and limited but did not exclude the expert's testimony.On appeal, the Supreme Court of Nevada reviewed the case. The court held that the district court did not clearly err in denying the Batson challenge at step one, as there was insufficient evidence of discriminatory purpose. The court found no Confrontation Clause violation in the substitute coroner’s testimony, as her opinion was based on independent review of admissible evidence. The court held that the limitation on the defense expert's testimony was erroneous under Nevada law but was harmless error. The court also found no abuse of discretion in providing the 911 call transcript to the jury and determined that no cumulative error warranted reversal. The Supreme Court of Nevada affirmed the conviction. View "MATADAMAS-SERRANO (RUBEN) VS. STATE" on Justia Law

The defendant, who had an extensive criminal history involving theft and related crimes, pleaded guilty to three counts of commercial burglary and one count of taking an automobile, and admitted to two prior strike convictions and various aggravating circumstances. He sought mental health diversion based on a psychologist’s evaluation that diagnosed him with several mental health disorders, including a major neurocognitive disorder due to brain injury, major depressive disorder, PTSD, ADHD, and opioid-use disorder in early remission. The defendant argued that these disorders compelled his repeated theft offenses.In the Superior Court of Santa Barbara County, the trial court considered the defendant’s request for mental health diversion under Penal Code section 1001.36. After reviewing the psychologist’s report and other evidence, the trial court found little to no evidence that the defendant’s mental health diagnoses were significant factors in the commission of the charged offenses. The court also found that the defendant would pose an unreasonable danger to public safety, in part due to his prior residential burglary convictions and ongoing criminality. Based on these findings, the trial court denied the request for mental health diversion and sentenced the defendant to twelve years in state prison.On appeal, the California Court of Appeal, Second Appellate District, Division Six, reviewed the trial court’s decision for abuse of discretion. The appellate court held that the trial court acted within its discretion by not crediting the psychologist’s opinion and by making adverse factual findings regarding the connection between the mental health diagnoses and the offenses. The appellate court affirmed the trial court’s denial of mental health diversion and upheld the judgment. View "People v. Nelson" on Justia Law

Following the discovery of Van Stevens’s brutal murder in Searcy, Arkansas, police identified Christopher Coy Gamble as a suspect based on his proximity to the crime and evidence tying him to the victim’s residence. Gamble, who was on parole at the time, was observed near the crime scene and was linked to incriminating items found at a neighbor’s property, including belongings previously returned to him by police. Surveillance footage, eyewitness accounts, and a custodial statement in which Gamble admitted being in the victim’s home further implicated him, although Gamble denied committing the murder.The White County Circuit Court conducted a jury trial, during which Gamble moved to suppress his custodial statement, arguing it resulted from a pretextual arrest, and sought to strike the venire after a potential juror expressed an opinion of his guilt. The circuit court denied both motions, finding no grounds for suppression or for striking the jury panel, and a jury subsequently convicted Gamble of capital murder and aggravated residential burglary, resulting in life and sixty-year sentences, respectively.The Supreme Court of Arkansas reviewed the case. On appeal, Gamble challenged the denial of his suppression motion, relying on State v. Sullivan, which barred pretextual arrests under the Arkansas Constitution. The Supreme Court of Arkansas overruled Sullivan, holding that Arkansas’s constitutional standard mirrors the federal “reasonableness” test: an arrest is lawful if supported by probable cause, regardless of the officer’s subjective motivation. The court concluded Gamble’s arrest was proper because he possessed drug paraphernalia in the officer’s presence. The court also found no abuse of discretion in denying Gamble’s motion to strike the venire, as the circuit court’s admonition sufficiently cured any potential prejudice. The Supreme Court of Arkansas affirmed Gamble’s convictions. View "GAMBLE v. STATE OF ARKANSAS" on Justia Law

The case involves a defendant who was recruited in Puerto Rico to act as a courier, transporting two suitcases containing approximately eleven kilograms of cocaine on a flight to Newark, New Jersey. Airport authorities in San Juan discovered the drugs before the defendant boarded the flight. After her arrest, she admitted to knowingly transporting the suitcases for a promised payment of $1,500, a sum far less than the drugs’ street value.Following her guilty plea to conspiracy and possession with intent to distribute cocaine, the United States District Court for the District of Puerto Rico sentenced her to forty-eight months in prison and forty-eight months of supervised release. The Probation Office recommended a three-level reduction in her Sentencing Guidelines offense level based on her minor or minimal role, highlighting other individuals who recruited her, organized the transport, and prepared the luggage. The government objected, arguing she was indispensable to the offense. The district court agreed with the government and denied the mitigating-role reduction, focusing primarily on her own conduct and the fact she was the one transporting the drugs.On appeal, the United States Court of Appeals for the First Circuit reviewed whether the district court properly conducted the required comparative culpability analysis under the Sentencing Guidelines. The appellate court held that the district court erred by failing to consider the roles of all participants in the criminal activity and by not applying the multi-step analysis clarified in United States v. Guía-Sendeme. The First Circuit vacated the sentence and remanded for resentencing so the district court could properly assess the defendant’s eligibility for a mitigating-role reduction, consistent with current precedent and the proper legal framework. View "United States v. Robles-Lopez" on Justia Law