Justia Criminal Law Opinion Summaries

Law enforcement arrested the defendant after discovering large quantities of methamphetamine and fentanyl in his vehicle. He was indicted for trafficking in methamphetamine and trafficking in illegal drugs under South Carolina law. The defendant entered a deferred plea agreement, agreeing to cooperate as a confidential informant in exchange for deferred sentencing. However, after being re-arrested on new drug charges, he ultimately pled guilty to both trafficking charges. Two years later, he moved to vacate his guilty plea to trafficking in illegal drugs, arguing that the statute under which he was charged did not criminalize trafficking in fentanyl, a synthetic opioid, and thus he had pled guilty to a nonexistent offense.The Circuit Court for Greenville County denied the motion to vacate, reasoning that the defendant had received a benefit by pleading to trafficking rather than a more serious charge and that his conduct was clearly criminal. The court did not specifically address whether fentanyl fell within the statutory language but imposed concurrent sentences for both trafficking convictions. The defendant appealed, contending that the indictment failed to state an offense and that the court lacked subject matter jurisdiction to accept his plea.The Supreme Court of South Carolina affirmed the conviction and sentence. The court held that even if the statute did not encompass fentanyl, any defect in the indictment was non-jurisdictional and was waived by the defendant’s guilty plea. The court clarified that subject matter jurisdiction is not implicated by defects in an indictment charging a recognized crime, and that a guilty plea waives all non-jurisdictional challenges. Therefore, the defendant could not challenge his conviction on the grounds asserted after pleading guilty. View "The State v. Sweet" on Justia Law

A city filed a criminal complaint against a property owner, alleging that his property was in violation of certain provisions of the International Property Maintenance Code (IPMC), which the city had adopted by ordinance. The complaint stated that the property’s residence lacked water service, had holes in the roof, and that a break wall was collapsing into a river. It also alleged the presence of various items described as “debris,” such as barrels, lawn mowers, boats, trailers, propane tanks, and overgrown vegetation. The city claimed these conditions violated IPMC sections requiring properties to be maintained in a “clean,” “safe,” and “sanitary” condition.The property owner moved to dismiss the charges in the Huron Municipal Court, arguing that the IPMC provisions were unconstitutionally vague because the terms “clean,” “safe,” and “sanitary” were undefined. The trial court agreed, relying on a prior decision from the Seventh District Court of Appeals, State v. ACV Realty, which had found similar IPMC language void for vagueness. As a result, the trial court dismissed the relevant counts. The city appealed, and the Sixth District Court of Appeals reversed, holding that the terms in question should be given their ordinary meanings and were sufficiently clear to inform property owners of the prohibited conduct.The Supreme Court of Ohio reviewed the case to resolve a conflict between appellate districts. The court held that a defendant cannot successfully challenge a law as void for vagueness if his conduct clearly falls within the activities the law prohibits. Because the alleged conditions of the property—such as lack of water, structural decay, and accumulation of debris—clearly violated the IPMC provisions, the property owner’s vagueness challenge failed. The Supreme Court of Ohio affirmed the appellate court’s judgment and remanded the case to the municipal court for further proceedings. View "Huron v. Kisil" on Justia Law

A man owned several pit bulls on his rural property near Texarkana, Texas. Despite a fence, the dogs repeatedly escaped and attacked people and animals in the area. After a series of incidents—including attacks on a neighbor’s horse and a woman on a scooter—the owner was formally notified by law enforcement that his dogs were considered dangerous under Texas law. Despite this notice, the dogs continued to escape and, in September 2022, attacked a ten-year-old boy, causing serious injuries that required surgery.The owner was indicted for injury to a child by omission, with the prosecution alleging he failed to restrain or enclose his dangerous dogs as required by Section 822.042(a) of the Texas Health and Safety Code. A jury in the trial court found him guilty and sentenced him to thirty-five years in prison. On appeal, the Sixth Court of Appeals reversed the conviction, holding that the State failed to prove the owner had a statutory duty to protect the child, reasoning that only duties arising from the Texas Family Code had previously been recognized for this type of offense.The Court of Criminal Appeals of Texas reviewed the case to determine whether Section 822.042(a) of the Texas Health and Safety Code can serve as a statutory duty to act for purposes of the injury to a child by omission statute. The court held that Section 822.042(a) does impose a mandatory statutory duty on owners of dangerous dogs to restrain or enclose them, and that this duty can be imported to satisfy the statutory duty element required for conviction under Penal Code Section 22.04(b)(1). The court reversed the judgment of the court of appeals and remanded the case for further proceedings. View "COCKRELL v. STATE OF TEXAS" on Justia Law

The case concerns a defendant who was charged with felony distribution of dangerous drugs in Montana, based on alleged conduct between July 2017 and February 2018. During pretrial proceedings, the State redacted portions of discovery materials, including a police report and a witness interview transcript, to exclude information not related to the defendant or not considered impeachment evidence. The witness in question, Ferguson, was facing federal charges and ultimately testified at trial that she had supplied the defendant with methamphetamine but denied receiving any promises or benefits for her testimony, aside from immunity from state charges.At trial in the Eighth Judicial District Court, several witnesses testified to the defendant’s involvement in drug transactions. Ferguson’s testimony was corroborative but not the sole evidence against the defendant. After the defendant’s conviction, a federal prosecutor filed a motion to reduce Ferguson’s sentence, citing her assistance in the defendant’s case. The defendant’s counsel was unaware of this at the time of trial and sentencing. The defendant later filed a petition for postconviction relief, arguing that the State violated its obligations under Brady v. Maryland by failing to disclose potential benefits to Ferguson and under Napue v. Illinois by not correcting her allegedly false testimony regarding those benefits. The District Court denied the petition, finding no evidence of a pretrial agreement or expectation of benefit that could be imputed to the State, and concluded that any non-disclosure was not material to the outcome.The Supreme Court of the State of Montana affirmed the District Court’s denial of postconviction relief. The Court held that, while evidence of a witness’s expectation of a benefit may be subject to disclosure, the record did not establish that such an expectation existed or that it could be imputed to the State prosecutor. Furthermore, the Court found that any non-disclosure was not material, as other substantial evidence supported the conviction. The Court also rejected the Napue claim, finding no basis to conclude the State knowingly allowed false testimony. View "Temple v. State" on Justia Law

The defendant was charged with eight offenses, including sexual abuse of children under 12 and incest. He entered into a plea agreement with the State, pleading guilty to all counts in exchange for the State’s agreement to recommend specific terms of incarceration for each offense. The plea agreement was silent regarding any restrictions on parole eligibility and expressly allowed only the defendant, not the State, to argue for any legal sentence.After the plea agreement was executed, the Seventh Judicial District Court, Dawson County, held a sentencing hearing. At that hearing, the State recommended a 40-year parole restriction, even though the agreement did not mention parole restrictions. The defendant did not object at the hearing but requested no parole restriction. The District Court ultimately sentenced the defendant to 75 years in prison, with a 40-year parole restriction, explicitly referencing the State’s recommendation in its decision.The Supreme Court of the State of Montana reviewed the case. Applying plain error review due to the lack of objection at sentencing, the court held that the prosecutor breached the plea agreement by recommending a parole restriction not contemplated by the agreement. The court distinguished this case from State v. Lewis, 2012 MT 157, because, unlike in Lewis, the plea agreement here did not allow the State to argue for any lawful sentence. The court found that the breach affected the fairness of the proceedings, as the District Court’s decision was explicitly based on the prosecutor’s improper recommendation. The Supreme Court of Montana reversed the District Court’s sentence and remanded for a new sentencing hearing before a different judge, ordering specific performance of the plea agreement. View "State v. Walton" on Justia Law

The case concerns Lloyd Mortier Barrus, who, along with his son Marshall, was involved in a series of violent events in Montana in May 2017. After a period of escalating paranoia and antigovernment rhetoric, Barrus and Marshall engaged in a high-speed chase and shootout with law enforcement, resulting in the death of Deputy Sheriff Mason Moore and the disabling of two police vehicles. Barrus was arrested after a standoff in which both he and Marshall fired at officers; Marshall was killed, and Barrus surrendered. Barrus was charged with deliberate homicide by accountability and two counts of attempted deliberate homicide by accountability.The First Judicial District Court, Broadwater County, presided over Barrus’s trial. Prior to trial, Barrus was found unfit to proceed due to a mental disorder but was later restored to fitness through involuntary medication. After a jury convicted Barrus on all counts, the court held a bifurcated evidentiary hearing to determine whether Barrus’s mental disease or disorder rendered him unable to appreciate the criminality of his conduct or to conform his behavior to the law, as required by § 46-14-311, MCA. Expert testimony was presented by both parties, with conflicting opinions regarding Barrus’s mental state at the time of the offense.The Supreme Court of the State of Montana reviewed whether the District Court abused its discretion by sentencing Barrus to the Department of Corrections (DOC) rather than the Department of Public Health and Human Services (DPHHS). The Supreme Court held that the District Court did not abuse its discretion, finding substantial evidence supported the conclusion that Barrus appreciated the criminality of his actions and could have conformed his conduct to the law. The judgment sentencing Barrus to DOC custody was affirmed. View "State v. Barrus" on Justia Law

In August 2021, the defendant, along with his brother and another accomplice, committed a series of crimes in Puerto Rico, including two carjackings and an armed robbery. During the first carjacking, a firearm was brandished at the victim, and the group later attempted a second carjacking, which was unsuccessful. That same night, the defendant and another individual robbed a bar, during which the defendant fired a gun both outside and inside the establishment. The defendant was arrested the following day, confessed to the attempted carjacking, and admitted to other criminal conduct that night.A grand jury indicted the defendant on two counts of carjacking and two counts of possession and brandishing a firearm in furtherance of a crime of violence. He entered into a plea agreement, pleading guilty to both carjacking counts and one count of possession of a firearm in furtherance of a crime of violence. The plea agreement contained errors regarding the total offense level for the carjacking counts and the maximum supervised release term for the firearm count. The presentence report corrected these errors, and neither party objected. At sentencing, the United States District Court for the District of Puerto Rico imposed sentences above those recommended by the parties, including an upward variance on the firearm count, citing the seriousness of the offenses and the defendant’s conduct.The United States Court of Appeals for the First Circuit reviewed the case. The court held that, although the defendant was misinformed about the supervised release term for the firearm count at the plea hearing, he was later correctly informed and failed to show a reasonable probability that this error affected his decision to plead guilty. The court also found no Rule 11 error regarding the sentencing range for the carjacking counts and concluded that the upwardly variant sentence for the firearm count was procedurally reasonable. The First Circuit affirmed the conviction and sentence. View "United States v. Morales-Ortiz" on Justia Law

A defendant was indicted for his role in a drug-trafficking organization operating across California, Georgia, and Nevada. He pleaded guilty to illegal reentry but not guilty to other charges, including conspiracy to possess with intent to distribute marijuana and possession with intent to distribute marijuana. At trial, the district court, over the defendant’s objection, empaneled an anonymous jury, concealing jurors’ names but allowing some personal information to be shared during voir dire. The government presented evidence of the defendant’s involvement in transporting cash and marijuana, and the defendant testified in his own defense, admitting to marijuana sales in California but denying involvement in the broader conspiracy alleged.The United States District Court for the Northern District of Georgia presided over the trial. The jury convicted the defendant of conspiracy to possess with intent to distribute less than 100 kilograms of marijuana and possession with intent to distribute marijuana, but acquitted him on money-laundering and firearm charges. At sentencing, the court attributed a significant drug quantity to the defendant, considered evidence including conduct for which he was acquitted, and imposed concurrent sentences of 120 months on each count, below the calculated guideline range. The defendant objected to the use of acquitted conduct and the calculation of the guideline range, but the court overruled these objections.The United States Court of Appeals for the Eleventh Circuit reviewed the case. It held that any error in empaneling an anonymous jury was harmless because several factors justified the measure and the court minimized prejudice. The appellate court also found no abuse of discretion in refusing a multiple-conspiracies instruction, held that considering acquitted conduct at sentencing was permissible under existing precedent, and concluded that the sentence imposed was both substantively and procedurally reasonable. The Eleventh Circuit affirmed the convictions and sentence. View "United States v. Touray" on Justia Law

A woman identified as E.J. was carjacked by two masked men in a Detroit store parking lot. She observed the men in the store, noting one was light-skinned and the other dark-skinned. After the incident, a store customer who knew the light-skinned man from school provided E.J. with his name and later sent both E.J. and the investigating officer photos and information from his Facebook profile. Before a police-arranged photo lineup, the customer sent E.J. a picture of the suspect, Kyrrah Radaker-Carter, despite police instructions not to do so. E.J. confirmed to the customer that the man in the photo was the carjacker. The next day, E.J. participated in a six-photo lineup and immediately identified Radaker-Carter, who was later arrested while driving the stolen car.The United States District Court for the Eastern District of Michigan denied Radaker-Carter’s motion to suppress E.J.’s identification, finding that due process did not require exclusion because the suggestive circumstances were not arranged by law enforcement and the photo array itself was not unduly suggestive. Radaker-Carter subsequently pleaded guilty and was sentenced to 122 months’ imprisonment, then appealed the suppression ruling.The United States Court of Appeals for the Sixth Circuit reviewed the district court’s factual findings for clear error and its legal conclusions de novo. The appellate court held that E.J.’s identification was constitutionally admissible because the suggestive circumstances—E.J. seeing Radaker-Carter’s photo before the lineup—were not orchestrated by law enforcement. The court also found that the police-arranged photo lineup was not unduly suggestive, as the differences in the photos were minor and did not improperly single out Radaker-Carter. The court affirmed the district court’s denial of the motion to suppress. View "United States v. Radaker-Carter" on Justia Law

A woman was convicted of first-degree murder in Maryland state court after being tried jointly with her husband. The prosecution’s case was largely circumstantial, focusing on motive and opportunity, and initially argued that she was the shooter. After her conviction, she moved for a new trial, alleging ineffective assistance of counsel. In support of her motion, she disclosed attorney-client privileged materials and testified about her defense strategy and communications with counsel. The trial court granted her a new trial but ordered her to turn over privileged materials to the State and allowed the same prosecution team, now privy to her defense strategy, to retry her case. The court also left open the possibility that her prior testimony could be used to impeach her if she testified at the new trial.On appeal, the Maryland Court of Special Appeals assumed, without deciding, that the trial court erred by allowing the same prosecution team to retry the case and by permitting the State to use information obtained from privileged materials. However, the appellate court found no prejudice, reasoning that the new evidence (including the existence of a second wig) did not harm her defense and that her decision not to testify was not prejudicial absent a proffer of her intended testimony. The Maryland Court of Appeals denied certiorari, and the United States Supreme Court also declined review.The United States Court of Appeals for the Fourth Circuit reviewed the case on habeas corpus. The Fourth Circuit held that the Maryland Court of Special Appeals’ finding of no prejudice was based on an objectively unreasonable determination of the facts, given the record showing the State’s use of privileged evidence and the impact on the defendant’s ability to testify. However, because the state appellate court had not actually decided whether a constitutional violation occurred, the Fourth Circuit vacated the district court’s denial of habeas relief and remanded for the district court to determine that question de novo. View "Kaur v. Warden" on Justia Law