Justia Criminal Law Opinion Summaries

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

A 16-year-old committed a violent home invasion, during which he raped, sodomized, and assaulted his former neighbor at knifepoint, then stole property from her home. He was convicted by a jury in 2002 of multiple counts, including forcible rape, oral copulation, sodomy, sexual battery, robbery, burglary, and related enhancements. His sentence was ultimately modified to a determinate term of 19 years, followed by a consecutive indeterminate term of 25 years to life, resulting in an effective sentence of 44 years to life.After serving more than 15 years, the defendant petitioned the Superior Court of Tulare County for recall and resentencing under California Penal Code section 1170(d)(1)(A), arguing that his sentence was the functional equivalent of life without parole (LWOP) and that, under equal protection principles as articulated in People v. Heard, he should be eligible for relief. The trial court denied the petition, finding that a 44-years-to-life sentence was not functionally equivalent to LWOP and thus did not qualify for resentencing under the statute.On appeal, the California Court of Appeal, Fifth Appellate District, considered whether the functional equivalency analysis from People v. Contreras, which was developed in the Eighth Amendment context, should apply to equal protection challenges under section 1170(d). The court declined to import the Eighth Amendment standard, instead applying a rational basis review as required for equal protection claims. The court held that the Legislature could rationally distinguish between juveniles sentenced to explicit LWOP and those with lengthy term-of-years sentences that do not guarantee death in prison. The court affirmed the trial court’s denial of the petition, holding that section 1170(d)’s limitation to those sentenced to LWOP does not violate equal protection as applied to a juvenile nonhomicide offender sentenced to 44 years to life. View "People v. Baldwin" on Justia Law

In this case, the defendant was shot five times in his apartment parking lot and, in the chaos, dropped his black iPhone and a satchel. His girlfriend took the satchel but left the phone, which was later recovered by police near some shrubs. The police also seized a different (white) iPhone from the defendant at the hospital. The black iPhone remained in police evidence for over two years, until it became relevant in a separate federal drug investigation. The government ultimately used data from the black iPhone, along with other evidence, to charge the defendant with drug trafficking, firearm offenses, and money laundering.The United States District Court for the District of Oregon presided over the trial. Before trial, the defendant moved to suppress evidence from the black iPhone, arguing that he retained a privacy interest in the device and its data, and also sought recusal of the district judge due to her prior service as U.S. Attorney when he was prosecuted for unrelated charges over fifteen years earlier. The district court denied both motions, finding that the defendant had abandoned the black iPhone and thus lacked standing to challenge its search, and that recusal was not warranted.The United States Court of Appeals for the Ninth Circuit reviewed the case. The Ninth Circuit disagreed with the district court’s finding that the defendant had abandoned his privacy interest in the black iPhone, holding that the circumstances—dropping the phone while fleeing after being shot—did not show intent to abandon the device or its data. However, the Ninth Circuit affirmed the denial of the suppression motion because federal agents obtained a warrant and searched the phone within a reasonable period. The court also affirmed the denial of the recusal motion, concluding that a reasonable person would not question the judge’s impartiality under these facts. The conviction and sentence were affirmed. View "USA V. HUNT" on Justia Law

Charles Sorensen, a retired airline pilot, engaged in a series of actions from 2016 to 2021 to evade federal income taxes for the years 2015 through 2019. His conduct included failing to file tax returns, submitting false returns, making fraudulent refund claims, concealing income and assets, and refusing to cooperate with the IRS. Sorensen used shell companies, such as LAWTAM and LAMP, to hide assets and income, transferred funds to avoid IRS levies, and ultimately converted assets into cryptocurrency to further shield them from collection. He also filed frivolous documents and lawsuits challenging the IRS’s authority. The total tax loss attributed to his actions was $1,861,722.A jury in the United States District Court for the District of Minnesota convicted Sorensen on seven counts, including filing false tax returns, tax evasion, failing to file tax returns, and making a false claim against the United States. The district court sentenced him to 41 months in prison. Sorensen appealed, arguing that the district court improperly admitted testimony from several witnesses who were not qualified as experts and erred in applying a sentencing enhancement for sophisticated means.The United States Court of Appeals for the Eighth Circuit reviewed the evidentiary rulings for abuse of discretion and the sentencing enhancement de novo. The appellate court held that the challenged witness testimony was properly admitted as lay testimony under Federal Rule of Evidence 701, as it was based on firsthand knowledge and personal experience, not specialized expertise. The court also found that the sophisticated means enhancement was appropriately applied, given Sorensen’s use of shell companies, cryptocurrency, and other complex methods to conceal his tax evasion. The Eighth Circuit affirmed the judgment of the district court. View "United States v. Sorensen" on Justia Law

Police officers responded to a call regarding an individual, McGuire, at a convenience store in Idaho Falls. After determining he was homeless and possibly under the influence, officers took him to a hospital for medical clearance and then to a behavioral health crisis center, where admission is voluntary. When McGuire failed to complete intake paperwork and did not leave when asked, officers attempted to escort him out. A physical altercation ensued, resulting in injuries to both officers. McGuire was charged with felony battery on a law enforcement officer and misdemeanor resisting or obstructing an officer. At trial, the evidence included officer testimony and body camera footage. McGuire did not testify and argued the State had not met its burden of proof.The Seventh Judicial District Court of Idaho denied McGuire’s motion for mistrial, which was based on statements by the prosecutor during closing argument that allegedly shifted the burden of proof to the defendant. The jury found McGuire guilty on both counts. McGuire was sentenced to one year fixed for the felony and fined for the misdemeanor. The Idaho Court of Appeals affirmed both convictions, and McGuire sought further review.The Supreme Court of the State of Idaho reviewed the case, giving due consideration to the Court of Appeals but directly reviewing the trial court’s decisions. The Supreme Court held that there was sufficient evidence to support the conviction for battery on a law enforcement officer, as officers were performing their duties when responding to the crisis center. However, the Court found insufficient evidence to support the conviction for resisting or obstructing an officer, as the State failed to prove the officers’ actions were lawful and authorized under the relevant statute. The Court also held that, although the prosecutor’s comments constituted misconduct, the trial court’s prompt corrective actions and jury instructions cured any resulting error. The Supreme Court affirmed the felony conviction and denial of the mistrial motion, but vacated the misdemeanor conviction. View "State v. McGuire" on Justia Law

Earl Miller, who owned and operated several real estate investment companies under the 5 Star name, was responsible for soliciting funds from investors, primarily in the Amish community, with promises that their money would be used exclusively for real estate ventures. After becoming sole owner in 2014, Miller diverted substantial investor funds for personal use, unauthorized business ventures, and payments to friends’ companies, all in violation of the investment agreements. He also misled investors about the nature and use of their funds, including issuing false statements about new business activities. The scheme continued even as the business faltered, and Miller ultimately filed for bankruptcy.A federal grand jury in the Northern District of Indiana indicted Miller on multiple counts, including wire fraud and securities fraud. At trial, the government presented evidence, including testimony from an FBI forensic accountant, showing that Miller misappropriated approximately $4.5 million. The jury convicted Miller on one count of securities fraud and five counts of wire fraud, acquitting him on one wire fraud count and a bankruptcy-related charge. The United States District Court for the Northern District of Indiana sentenced Miller to 97 months’ imprisonment, applying an 18-level sentencing enhancement based on a $4.5 million intended loss, and ordered $2.3 million in restitution to victims.The United States Court of Appeals for the Seventh Circuit reviewed Miller’s appeal, in which he challenged the district court’s loss and restitution calculations. The Seventh Circuit held that the district court reasonably estimated the intended loss at $4.5 million, as this amount reflected the funds Miller placed at risk through his fraudulent scheme, regardless of when the investments were made. The court also upheld the restitution award, finding it properly included all victims harmed by the overall scheme. The Seventh Circuit affirmed the district court’s judgment. View "USA v Miller" on Justia Law