Justia Criminal Law Opinion Summaries

A group of family members was attacked after being mistaken for rival gang members by individuals associated with the Dragon Family/Dragon Family Junior gang in Orange County. After being followed from a restaurant, their car was cornered in a cul-de-sac, and a shooter fired multiple shots into the vehicle, killing a 13-year-old and injuring two others. Several gang members were apprehended soon after, while the defendant was arrested months later in Arizona. At trial, accomplice testimony, forensic evidence, and writings attributed to the defendant were presented to establish his identity as the shooter and his gang affiliation.The Orange County Superior Court jury convicted the defendant of murder, two counts of attempted murder, and active participation in a criminal street gang, with various firearm and gang-related enhancements. The jury found true a special circumstance that the murder was committed to further gang activities and returned a death verdict. The trial court denied the defendant’s motion to modify the verdict. The defendant raised several claims on appeal, including challenges to jury selection under Batson and Wheeler, the sufficiency of accomplice corroboration, the handling of third-party culpability evidence, the admission of creative writings, the denial of a continuance, and alleged prosecutorial misconduct.The Supreme Court of California reviewed the case. It held that retroactive changes to the law under Assembly Bill 333, which heightened the requirements for proving a “pattern of criminal gang activity,” applied to the defendant’s case. The Court found that the jury had not been instructed under the new, stricter standard, and the Attorney General conceded this error was prejudicial. As a result, the conviction for active gang participation, all gang enhancements, and the gang-murder special circumstance were reversed, requiring reversal of the death judgment. The Court otherwise affirmed the judgment, finding no merit in the defendant’s other claims. The case was remanded for further proceedings. View "P. v. Aguirre" on Justia Law

Lester Thompson Jr. was charged with the murder of Destinie Gates-Jackson, with whom he had a long-term relationship. After previously being convicted of kidnapping and assaulting Ms. Gates-Jackson, Thompson was found driving a car containing her body, and forensic evidence indicated she died from strangulation. Thompson’s defense at trial was that Ms. Gates-Jackson died from an underlying health condition, not homicide, and he sought to subpoena her medical records to support this theory. Jeri Gates, the decedent’s mother and representative, intervened to oppose the release of these records, citing privacy concerns. The trial court denied Thompson’s motions to subpoena the records, and he was convicted of second-degree murder with a domestic violence finding.Thompson appealed his conviction to the Washington Court of Appeals, arguing, among other things, that the trial court erred in denying his request for the medical records. Ms. Gates moved to intervene in the appeal solely on the issue of the medical records, and the Court of Appeals granted her motion over Thompson’s objection. Thompson then sought review by the Supreme Court of the State of Washington, contending that the appellate court erred in permitting Ms. Gates to intervene.The Supreme Court of the State of Washington held that when a trial court has allowed a nonparty to intervene to protect a legally cognizable interest, an appellate court has the discretion to permit that nonparty to intervene on appeal, provided the intervention is limited to the same issues addressed below. The court affirmed the Court of Appeals’ decision, concluding that the appellate intervention was proper under these circumstances and within the appellate court’s discretionary authority. View "State v. Thompson" on Justia Law

Gladys Perez was convicted in Nevada state court of first-degree murder, child neglect, and child abuse, and sentenced to life in prison with the possibility of parole. After her conviction was affirmed by the Supreme Court of Nevada and became final in May 2012, Perez filed a state post-conviction habeas petition, which tolled the federal one-year limitations period under the Antiterrorism and Effective Death Penalty Act (AEDPA). Her state petition was denied in December 2013, and Perez repeatedly instructed her court-appointed attorney, Bret Whipple, to file an appeal. Whipple failed to communicate with Perez or file the appeal, and did not provide her with the necessary case documents. After months of unsuccessful attempts to contact Whipple, Perez began preparing a federal habeas petition on her own, facing additional obstacles such as limited access to the prison law library, incomplete case files, and delays in obtaining a required financial certificate from prison officials.The United States District Court for the District of Nevada dismissed Perez’s federal habeas petition as untimely, finding that she had not demonstrated the extraordinary circumstances or reasonable diligence required for equitable tolling under AEDPA. The district court concluded that Perez’s efforts to contact her attorney and prepare her petition were insufficient to excuse her late filing.On appeal, the United States Court of Appeals for the Ninth Circuit reversed the district court’s dismissal. The Ninth Circuit held that Perez’s abandonment by her post-conviction counsel constituted an extraordinary circumstance that prevented her timely filing, and that she acted with reasonable diligence both before and after the abandonment. The court also found that delays by prison officials in processing her financial certificate further contributed to her late filing. The panel concluded that Perez qualified for equitable tolling and remanded the case for consideration of the merits of her habeas petition. View "PEREZ V. REUBART" on Justia Law

While serving a forty-year sentence at Mayo Correctional Institution, Jesse Bell and his cellmate planned and executed the murder of another inmate as a rehearsal for a subsequent planned attack on a correctional officer. On June 26, 2019, they killed the inmate and later that day attempted to kill the officer, who survived. Bell confessed to the crimes and was indicted for first-degree murder, attempted murder, conspiracy, and possession of contraband. Shortly after counsel was appointed, Bell waived his right to counsel and a penalty-phase jury, entered a no-contest plea, and represented himself during sentencing. The court found multiple aggravating factors and sentenced Bell to death.The Circuit Court for Lafayette County conducted the trial and sentencing. On direct appeal, the Supreme Court of Florida affirmed Bell’s conviction and death sentence, finding his waivers and plea were knowing and voluntary, and that he was not deprived of an individualized sentencing. Bell then filed a motion for postconviction relief under Florida Rule of Criminal Procedure 3.851, arguing his waivers were involuntary due to prison abuse, that counsel was ineffective for not investigating this abuse, and that he was denied individualized sentencing. The circuit court summarily denied the motion, finding the claims procedurally barred or refuted by the record.The Supreme Court of Florida reviewed the summary denial and Bell’s habeas petition. The court held that Bell’s postconviction claims were procedurally barred because they could have been raised on direct appeal, and that the record showed his waivers were voluntary. The court also found no ineffective assistance of counsel or appellate counsel, as there was no evidence of prejudice or deficient performance. The order denying postconviction relief was affirmed, and habeas relief was denied. View "Bell v. State of Florida" on Justia Law

The defendant pled guilty to possession of a firearm and ammunition after a felony conviction. At sentencing, the United States District Court for the Eastern District of New York imposed a term of imprisonment followed by supervised release. During the sentencing hearing, the court orally imposed several “special” conditions of supervised release, as recommended in the presentence report, but did not specify or discuss any “standard” or additional discretionary conditions. The court also stated that the defendant would not be required to contribute to the cost of mental health services, contrary to a recommendation in the presentence report. However, the written judgment later included not only the special conditions but also thirteen additional discretionary “standard” conditions of supervised release, as well as a requirement that the defendant contribute to mental health service costs.After sentencing, the defendant appealed, arguing that his constitutional right to be present at sentencing was violated because the thirteen discretionary conditions were not pronounced in his presence, and that the written judgment’s requirement to pay for mental health services contradicted the oral sentence. Both parties agreed that the payment requirement should be eliminated due to this inconsistency.The United States Court of Appeals for the Second Circuit, sitting en banc, reviewed the case de novo. The court overruled its prior precedent in United States v. Truscello, which had allowed non-mandatory “standard” conditions to be added to the written judgment without oral pronouncement. The Second Circuit held that all non-mandatory conditions of supervised release, including those labeled as “standard” in the Sentencing Guidelines, must be pronounced in the defendant’s presence at sentencing. The court vacated the portions of the sentence imposing the thirteen discretionary conditions and the payment requirement, and remanded the case for further proceedings consistent with its opinion. View "United States v. Maiorana" on Justia Law

A man was charged with multiple counts of first- and second-degree child sex abuse and related offenses, based on allegations that he repeatedly sexually assaulted his then-girlfriend’s young daughter over a period of nearly two years. The complainant, who was nine to ten years old at the time of the alleged abuse, disclosed the assaults to her mother about ten months after the accused moved out of their home. Upon learning of the allegations, the mother, who was a police officer, recorded a nearly twenty-minute video of her conversation with her daughter, in which the child described the alleged abuse in detail, including some claims not raised at trial and references to uncharged violent conduct. Both the complainant and her mother testified at trial, and the prosecution sought to admit the entire recording as evidence.The Superior Court of the District of Columbia admitted the full recording under the “report-of-rape” rule, over the defendant’s objection, and instructed the jury that the recording was not to be considered for the truth of its contents but rather to show that a report was made and to evaluate the demeanor of the witnesses. The jury found the defendant guilty on several counts, and he was sentenced to 384 months in prison. The defendant appealed, arguing that admitting the entire recording was erroneous and prejudicial.The District of Columbia Court of Appeals held that the trial court erred by admitting the entire recording, as the “report-of-rape” rule only allows for the admission of enough details to show that a report was made, not the full substance or highly prejudicial content. The court found the error was not harmless and reversed the convictions, remanding the case for further proceedings. View "Johnson v. United States" on Justia Law

The case concerns an incident in which the appellant shot his longtime friend during an argument over a small debt. The altercation escalated when the appellant, sitting in his car, pointed a gun at the friend and fired three shots, injuring him. The friend fled, and the appellant left the scene, later crashing his car. Police identified and arrested the appellant about six weeks after the shooting. He was indicted for assault with intent to kill and related firearm offenses.During pretrial proceedings in the Superior Court of the District of Columbia, the appellant notified the court and the government of his intent to raise an insanity defense. He provided notice that his expert, Dr. Lally, would testify that the appellant met the legal standard for insanity, basing his opinion largely on a report by Dr. Grant, which detailed the appellant’s history of severe mental illness and hospitalizations but did not reach a definitive conclusion on insanity. The government argued that the expert notice was insufficient under Rule 16 and moved to preclude Dr. Lally’s testimony. The trial court agreed, finding the notice deficient and, without allowing the appellant an opportunity to cure the issue, barred Dr. Lally from testifying. As a result, the appellant abandoned his insanity defense. The trial proceeded on the issue of guilt, and the jury convicted the appellant of aggravated assault while armed and related offenses, acquitting him of the most serious charge.On appeal, the District of Columbia Court of Appeals held that the appellant’s expert notice satisfied the requirements of Rule 16 as it existed at the time. The court further found that, even if there had been a deficiency, the trial court’s sanction of precluding the expert was disproportionate and an abuse of discretion, especially since the appellant was not given a chance to cure any perceived defect. The court provisionally vacated the convictions and remanded for a new trial limited to the insanity defense. If the jury finds the appellant not guilty by reason of insanity, the convictions remain vacated; otherwise, the convictions may be reinstated. The court also found no reversible error in the trial court’s handling of the self-defense instruction. View "Farmer v. United States" on Justia Law

A law enforcement agency in the District of Columbia, responsible for supervising individuals on supervised release, imposed GPS monitoring on a supervisee without judicial or Parole Commission authorization. The agency’s internal regulations permitted its officers to unilaterally require GPS monitoring as an administrative sanction, and this practice had been applied to thousands of supervisees over two decades. In this instance, the supervisee was placed on GPS monitoring twice, first for a positive drug test and then for submitting questionable urine samples. Subsequently, police investigating an armed robbery used the agency’s GPS data to identify and locate the supervisee, leading to his arrest and the recovery of stolen property and a firearm.The Superior Court of the District of Columbia reviewed the supervisee’s motion to suppress the GPS evidence and its fruits, following the District of Columbia Court of Appeals’ recent decision in Davis v. United States, 306 A.3d 89 (D.C. 2023), which held that the agency lacked statutory authority to impose GPS monitoring absent judicial or Parole Commission approval, rendering such searches unconstitutional. The government conceded the constitutional violation but argued that the good faith exception to the exclusionary rule should apply, as the agency reasonably relied on its own regulations. The trial court rejected this argument and granted the suppression motion.On appeal, the District of Columbia Court of Appeals affirmed the trial court’s ruling. The court held that the exclusionary rule applies because the agency is a law enforcement entity, not a neutral third party like a judge or legislature, and thus should feel the deterrent effect of suppression. The good faith exception does not apply when a law enforcement agency unilaterally authorizes unconstitutional searches based on its own mistaken interpretation of its authority. The court concluded that suppression is warranted to deter systemic constitutional violations. View "United States v. Wells" on Justia Law

The case concerns a petitioner who was convicted of first degree murder and aggravated discharge of a firearm following a bench trial in the Circuit Court of Cook County. The incident involved a drive-by shooting in which the victim was killed, and the petitioner, a member of the Satan Disciples gang, was accused of firing the shots. The prosecution presented eyewitness testimony and police evidence, while the petitioner maintained his innocence, claiming he was at home with family at the time of the shooting. The trial court found the petitioner guilty and imposed a lengthy prison sentence.After his conviction was affirmed on direct appeal by the Appellate Court of Illinois, First District, and further review was denied by both the Illinois Supreme Court and the United States Supreme Court, the petitioner pursued postconviction relief. He filed multiple postconviction petitions alleging ineffective assistance of counsel and actual innocence, supported by affidavits from family members and other witnesses. The circuit court dismissed these petitions, finding the claims either waived, not credible, or insufficient under the applicable legal standards. The appellate court later reversed the dismissal of a successive postconviction petition, finding a substantial showing of actual innocence and remanded for a third-stage evidentiary hearing. Importantly, the appellate court ordered, sua sponte, that the case be assigned to a different judge on remand, citing interests of justice and concerns about the prior judge’s handling of the case.The Supreme Court of Illinois reviewed whether the appellate court had authority to order reassignment to a new judge on remand for reasons other than bias, potential bias, or prejudice. The court held that, in postconviction proceedings, an appellate court may only order reassignment to a new judge sua sponte if the record clearly reveals bias, the probability of bias, or prejudice by the trial judge. The court found no such circumstances in this case and reversed the appellate court’s order for reassignment, affirming in part and reversing in part, and remanded the cause to the circuit court. View "People v. Class" on Justia Law

A 17-year-old defendant was charged with ten serious offenses, including murder and assault, after a violent confrontation at the home of his rivals. The incident stemmed from a feud with a classmate and escalated when the defendant, accompanied by his family, armed himself and attacked the victims’ home. The attack resulted in the death of one individual and severe injuries to others. The defendant, an enrolled member of the Cherokee Nation, was charged under federal law for crimes committed within the Cherokee Nation Indian Reservation.The United States District Court for the Eastern District of Oklahoma first reviewed the case. The government moved to transfer the defendant from juvenile to adult criminal proceedings under the Juvenile Justice and Delinquency Prevention Act. After an evidentiary hearing, the magistrate judge recommended granting the transfer, and the district court adopted this recommendation after conducting a de novo review. The district court weighed the statutory factors, including the defendant’s age, social background, psychological maturity, prior delinquency record, past treatment efforts, and the availability of rehabilitative programs, and found that most factors favored transfer to adult status.On interlocutory appeal, the United States Court of Appeals for the Tenth Circuit reviewed the district court’s decision for abuse of discretion. The appellate court held that the district court did not abuse its discretion in weighing the statutory transfer factors and found no clear error in its factual findings. The court also rejected the defendant’s Eighth Amendment argument that transfer was unconstitutional due to the potential punishments, holding that the challenge was unripe under circuit precedent. The Tenth Circuit affirmed the district court’s order transferring the defendant to adult criminal proceedings. View "United States v. J.D.V., Jr." on Justia Law