Justia Criminal Law Opinion Summaries

The case involved a former attorney who was tried and convicted in 2023 for the murders of his wife and son, as well as for possession of a weapon during the commission of a violent crime. The trial was widely publicized and lasted six weeks. After his conviction and sentencing to life in prison, the defendant filed a motion for a new trial, alleging that the Colleton County Clerk of Court had improperly influenced the jury by making comments that disparaged his credibility and suggested he was guilty, as well as by pressuring the jury to reach a guilty verdict. Affidavits and testimony from several jurors and court staff supported claims that the clerk made these comments, motivated in part by a desire for notoriety and book sales.A post-trial court, presided over by a different judge due to the original judge’s recusal, held a hearing to examine the alleged improper communications. The post-trial court found that the clerk had made improper comments to the jury, but concluded these did not affect any juror’s verdict and denied the motion for a new trial. The defendant appealed, and the South Carolina Supreme Court certified the appeal and consolidated it with the direct appeal of the convictions.The Supreme Court of South Carolina reversed the post-trial court’s denial of a new trial. The court held that the clerk’s comments constituted improper external influence on the jury, triggering a presumption of prejudice under the Remmer v. United States standard. The court found that the State failed to rebut this presumption, and further held that the post-trial court erred by questioning jurors about the effect of the comments in a manner prohibited by evidentiary rules. The Supreme Court ordered a new trial and provided guidance for the admissibility of evidence related to the defendant’s financial crimes on remand. View "The State v. Murdaugh" on Justia Law

The defendant, a convicted felon, was living at a multi-unit residence with his girlfriend and her family in New Hampshire. After an altercation involving a damaged car mirror and escalating tensions with a family friend, the defendant brought a loaded pistol outside, intending to confront the friend. During a heated exchange, the defendant fired two shots, killing the family friend and seriously injuring his girlfriend’s uncle. He was arrested later that day and subsequently charged in federal court with possessing a firearm and ammunition as a convicted felon under 18 U.S.C. §§ 922(g)(1) and 924(e).Prior to trial in the United States District Court for the District of New Hampshire, the defendant sought to present affirmative justification defenses, including duress, necessity, and self-defense. He also moved to dismiss the indictment, claiming that the application of § 922(g)(1) violated his Second Amendment rights as applied to his circumstances. The district court held an evidentiary hearing and ultimately ruled that the defendant had failed to make a sufficient threshold showing to present a justification defense to the jury. It also denied his motion to dismiss. The defendant entered a conditional guilty plea, reserving his right to appeal these rulings and later challenged his above-Guidelines sentence as substantively unreasonable.The United States Court of Appeals for the First Circuit reviewed the district court’s rulings and affirmed. The court held that the defendant failed to meet the threshold requirements for a justification defense under established circuit precedent and common law standards. The court further concluded that the defendant’s Second Amendment as-applied challenge lacked merit given the facts, and upheld the district court’s denial of the motion to dismiss. Finally, the First Circuit found the above-Guidelines sentence was justified and not substantively unreasonable. The conviction and sentence were affirmed. View "US v. Fort" on Justia Law

Rami Mhana operated businesses that purchased fraudulently obtained Apple iPhones and other electronics at below-market prices, paying in cash and often shipping these goods overseas in bulk. His suppliers included individuals who acquired electronics using stolen personal information to make purchases from major retailers and wireless carriers. Mhana did not verify his suppliers’ identities or the legitimacy of the goods, nor did he provide receipts. He also paid third-party services to unlock phones, enabling their use on any network. The government’s investigation began after a ruptured overseas shipment revealed the scheme, ultimately leading to the discovery of thousands of fraudulent transactions.A federal grand jury in the United States District Court for the Western District of North Carolina indicted Mhana on multiple counts, including transportation of stolen goods, conspiracy, and money laundering. Following a six-day trial, the jury convicted him on all charges. The indictment included a forfeiture notice, and the jury found a nexus between certain property and Mhana’s crimes. The district court initially granted a preliminary order of forfeiture but, at sentencing, declined to enter a final forfeiture judgment, citing concerns about double payment with restitution. The district court entered final judgment, prompting Mhana to appeal his convictions and the government to cross-appeal the forfeiture ruling.The United States Court of Appeals for the Fourth Circuit reviewed the case. It affirmed Mhana’s convictions, finding no reversible error in the district court’s evidentiary rulings, and determined that any assumed errors were harmless given the overwhelming evidence of guilt. However, the appellate court reversed the district court’s denial of forfeiture, holding that forfeiture is mandatory under federal law when the statutory prerequisites are satisfied, even if restitution is also imposed, and remanded the case for entry of a forfeiture judgment. View "US v. Mhana" on Justia Law

The defendant was arrested in March 2021 for unlawfully possessing a firearm as a convicted felon after a police encounter outside a convenience store. During the arrest, he resisted and threatened officers, and was found in possession of a loaded ghost gun and distributable amounts of fentanyl. He was charged with possession of ammunition as a convicted felon and possession with intent to distribute fentanyl, ultimately pleading guilty to the ammunition charge. At sentencing, the court weighed the seriousness of his offense and history, including his mental health issues and young age, and imposed a within-Guidelines sentence of 70 months' imprisonment.After sentencing, a retroactive amendment to the Federal Sentencing Guidelines (Amendment 821) reduced the impact of "status points," lowering the defendant's criminal history category and decreasing his advisory Guidelines range from 57-71 months to 51-63 months. In March 2024, he moved for a sentence reduction under 18 U.S.C. § 3582(c)(2), citing rehabilitation efforts while incarcerated. The government opposed, documenting three disciplinary violations by the defendant in prison, including threatening prison staff.The United States District Court for the Eastern District of Virginia found the defendant eligible for a reduction but denied the motion, concluding that the relevant § 3553(a) factors and his disciplinary record weighed against a reduction. The United States Court of Appeals for the Fourth Circuit reviewed the denial for abuse of discretion. The court held that a sentence reduction motion does not trigger a plenary resentencing or require a detailed explanation for retaining a sentence above the amended Guidelines range. The district court’s acknowledgment and consideration of relevant factors sufficed. The Fourth Circuit affirmed the district court’s decision, finding no abuse of discretion and that the presumption of judicial consideration was not rebutted. View "US v. Davis" on Justia Law

A defendant, who co-founded an animal rights organization, participated in “open rescues” at two poultry farms in Sonoma County, California. These actions involved entering private property without permission to document suspected animal cruelty and, in some cases, removing animals believed to be suffering. The defendant relied on legal and veterinary opinions suggesting his actions were justified to prevent harm to the animals. He was charged with felony conspiracy to commit trespass, misdemeanor trespass, and related offenses, arising from two incidents at Sunrise Farms and Reichardt Duck Farm.The case was tried in the Superior Court of Sonoma County. The defendant represented himself and sought to present a necessity defense, arguing he believed his conduct was lawful based on legal advice. The trial court ruled the necessity defense legally unavailable, finding no emergency or imminent threat justifying trespass. It also restricted the mistake of law defense, limiting it to a statutory provision that allowed trespass only to provide food or water to animals deprived for over 12 hours. The jury convicted the defendant on most counts, except one which was dismissed after a hung verdict. The defendant appealed, raising issues about the exclusion of his necessity defense, the limited mistake of law instruction, and constitutional challenges to the statutes involved.The Court of Appeal of the State of California, First Appellate District, Division Five, reviewed the case. It held that the trial court erred by excluding evidence and jury instructions on the defendant’s good faith mistake of law based on necessity, which was relevant to the specific intent crimes charged. The appellate court reversed the convictions for conspiracy to commit trespass and trespass with intent to interfere with a business, remanding for further proceedings. The conviction for trespass by refusing to leave property was affirmed. The court rejected constitutional challenges to the relevant statutes. View "P. v. Hsiung" on Justia Law

A fifteen-year-old boy, J.S., was approached by Javier Vega Dominguez at a Walmart and offered money in exchange for selling pornographic materials and performing sexual acts. J.S. declined and, with his father, reported the incident to police. Law enforcement then conducted an undercover operation, during which Vega Dominguez engaged in explicit communications with a detective posing as J.S., ultimately leading to his arrest when he arrived at an arranged meeting. Vega Dominguez was charged with soliciting for child prostitution, sexual exploitation of a child, criminal attempt to commit patronizing a prostituted child, and criminal attempt to commit inducement of child prostitution.Following a jury trial in the district court, Vega Dominguez was convicted on all four counts. He was sentenced to concurrent terms for three of the counts, with the sentence for sexual exploitation to run consecutively. On appeal to the Colorado Court of Appeals, Vega Dominguez argued that his conviction for attempted patronizing a prostituted child violated equal protection because it punished the same conduct as attempted inducement of child prostitution but carried a more severe penalty. He also challenged the trial court’s jury instructions, arguing the mens rea for soliciting for child prostitution should be “intentionally” rather than “knowingly.” The Court of Appeals agreed with him on the equal protection claim and vacated that conviction, but upheld the rest.The Supreme Court of Colorado reviewed these decisions. It held that any error regarding the equal protection claim was not “plain” because it was not obvious under existing law, reversing the Court of Appeals’ judgment and vacating its merits analysis on that question. The court also held, consistent with its precedent in Randolph v. People, that the correct mental state for soliciting for child prostitution is “knowingly,” and that the jury was properly instructed when all instructions were read together. The Supreme Court of Colorado affirmed the conviction for soliciting for child prostitution and reversed the judgment vacating the attempted patronizing conviction. View "People v. Dominguez" on Justia Law

The defendant, a person of Mexican descent, worked at a tax preparation business serving Spanish-speaking clients in Boise, Idaho. He was indicted on seven counts of preparing and presenting false and fraudulent tax returns. During jury deliberations, it became undisputed that one juror made racially biased comments about Mexicans. This juror, identified as Juror 5, participated in nearly all deliberations and expressed views suggesting animus toward Mexicans, including remarks about how Mexicans "hate Americans" and allegations connecting the defendant's employer to criminal activity.After the biased statements were reported, the United States District Court for the District of Idaho conducted a special voir dire with all jurors to determine the impact of the comments. Several jurors confirmed hearing the remarks, but most denied being influenced by them. The district court excused Juror 5 for good cause but allowed the remaining eleven jurors to continue deliberations without instructing them to start anew. Thirteen minutes later, the jury returned a partial verdict. The defendant moved for a mistrial and later for a new trial, arguing that his Sixth Amendment right to an impartial jury was violated. The district court denied both motions, applying the standard from United States v. Sarkisian, which asks whether exposure to prejudicial comments tainted the verdict.On appeal, the United States Court of Appeals for the Ninth Circuit held that the district court applied an incorrect legal standard. The Ninth Circuit concluded that the proper standard is from United States v. Remmer, which presumes prejudice when juror bias is discovered before a verdict is accepted, and places a heavy burden on the government to prove harmlessness. The court found that the government failed to rebut this presumption, and therefore reversed the district court’s denial of the motion for a new trial and remanded for a new trial. View "USA V. SANCHEZ" on Justia Law

The case involves a defendant who pleaded guilty to multiple serious offenses, including lewd conduct with a minor under sixteen, possession of sexually exploitative material, and injury to a child. The underlying facts revealed that the defendant, while already on probation for prior felonies, sexually abused his thirteen-year-old daughter over a prolonged period, starting when she was eleven. The investigation uncovered incriminating text messages, images of child sexual abuse material, and physical evidence corroborating the victim’s statements. The defendant accepted a plea agreement resulting in the dismissal of several charges and enhancements.Following the plea, the defense requested a presentence investigation (PSI), a psychosexual evaluation (PSE), a polygraph, and a mental health evaluation. Although the district court ordered these, the PSE and polygraph were not completed before the scheduled sentencing hearing due to defense counsel’s oversight. At sentencing, the defense orally moved to continue the hearing to allow completion of these evaluations, arguing they might provide mitigating evidence. The State did not object, but the district court denied the continuance, emphasizing the lack of demonstrated effort to timely secure the evaluations and the unlikely prospect of probation given the egregious facts. The court then imposed a fixed life sentence for lewd conduct and three concurrent ten-year sentences for the remaining offenses.On appeal, the Supreme Court of the State of Idaho reviewed whether the district court abused its discretion in denying the continuance and imposing a fixed life sentence. Applying established standards, the Supreme Court held that the district court acted within its discretion. The court found no due process violation, noting that neither Idaho law nor precedent guarantees a defendant a continuance to pursue potentially favorable evidence when there is a lack of diligence. The Supreme Court also concluded that the fixed life sentence was within statutory limits and appropriately weighed the seriousness of the offenses and the risk to society. The judgment was affirmed. View "State v. Gutierrez" on Justia Law

Antonio Evans was indicted on six counts, including conspiracy to distribute and distribution of a controlled substance under federal law. These offenses allow for enhanced mandatory minimum sentences if the defendant has a prior “serious drug felony.” Evans previously was convicted under Iowa law for possession with intent to deliver cocaine, an offense meeting the statutory criteria for a serious drug felony if additional facts are established: that Evans served more than 12 months in prison and was released within 15 years before the new offense. The government filed notice before trial to seek the enhancement, and both parties requested jury instructions on the incarceration-related facts, but the district court did not submit those facts to the jury.After Evans’s conviction, and before sentencing, the Supreme Court decided Erlinger v. United States, clarifying that the Sixth Amendment requires a jury to find incarceration-related facts for such enhancements. Evans objected to the enhancement, asserting it could not be applied since no jury had found those facts. The United States District Court for the Northern District of Iowa agreed and initially planned to empanel a jury, but then vacated that order, concluding that the statutory procedure under 21 U.S.C. § 851 required the court—not a jury—to resolve the objection, creating a procedural conflict with the Sixth Amendment. The court set sentencing without the enhancement.The United States Court of Appeals for the Eighth Circuit reviewed this de novo. It held that, in this procedural posture, neither the court nor a jury could constitutionally or statutorily find the incarceration-related facts necessary to apply the enhanced mandatory minimum. The court affirmed the district court’s decision to sentence Evans without the enhancement, ruling that applying it would violate either Evans’s Sixth Amendment rights or federal statutory requirements. View "United States v. Evans" on Justia Law

Federal authorities investigated a man after discovering that his co-defendant, who had been involved in two separate shooting incidents, had purchased a firearm for him. The defendant was charged with illegal receipt of a trafficked firearm based on this transaction. He pleaded guilty to that charge and was released pending sentencing, but while on bail, he was alleged to have participated in an assault and attempted robbery at a gas station, leading to the revocation of his bail.The United States District Court for the District of Connecticut held a sentencing hearing, during which it imposed a sentence of 30 months’ imprisonment—substantially above the advisory Sentencing Guidelines range of 12 to 18 months. The district court based its decision in part on the defendant’s alleged uncharged conduct while on bail and on the violent conduct of the co-defendant, specifically the two shootings. The district court reasoned that these incidents provided relevant context for the nature and circumstances of the defendant’s offense, even though there was no evidence that the defendant participated in or was aware of the co-defendant’s shootings, and no finding was made regarding the reliability or proof of the uncharged conduct by the defendant.On appeal, the United States Court of Appeals for the Second Circuit held that the district court plainly erred by considering the co-defendant’s prior violent activities in sentencing the defendant. The Second Circuit found there was no basis to attribute the co-defendant’s shootings to the defendant under any sentencing factor, as they were not part of a joint undertaking or conspiracy and were not shown to be relevant to the defendant’s conduct. The court vacated the sentence and remanded for a full resentencing, instructing the district court not to consider the co-defendant’s unrelated violent acts and clarifying the process for addressing any alleged uncharged conduct by the defendant. View "United States v. Dralle" on Justia Law