Justia Criminal Law Opinion Summaries

Philadelphia police officers stopped a car driven by Raphael Ross for having illegally tinted windows in a high-crime area. During the stop, Ross appeared extremely nervous, displaying shaking hands, a stammering voice, and erratic movements with his jacket inside the car. After Ross produced expired insurance and registration and claimed to have left his license elsewhere, Officer Smart complimented Ross’s Rolex watch and asked where he worked. Ross replied that he owned a home health aide business. Officer Smart then returned to his patrol car to check Ross’s information, discovering a recent firearm arrest. Meanwhile, Officer Foreman observed continued nervous behavior and noncompliance with her instructions. After backup arrived, officers frisked Ross and searched his car, finding a gun and drugs.Ross was charged in the United States District Court for the Eastern District of Pennsylvania with firearm and drug offenses. He moved to suppress the evidence, arguing that the officer’s questions about his watch and employment unlawfully extended the stop under the Fourth Amendment, as interpreted by Rodriguez v. United States. The District Court denied the motion, finding the brief exchange to be permissible small talk aimed at calming Ross and not an unconstitutional extension of the stop. Ross pleaded guilty but reserved his right to appeal the suppression ruling.The United States Court of Appeals for the Third Circuit reviewed the case. The court held that brief, safety-related small talk—such as complimenting a watch and asking about employment—does not violate the Fourth Amendment if it is intended to deescalate tension and does not measurably prolong the stop. The court found that the officers’ actions were reasonable given Ross’s nervous behavior and affirmed the District Court’s denial of the suppression motion and Ross’s conviction. View "USA v. Ross" on Justia Law

In March 2022, police officers in Providence responded to concerns about Sherbert Maddox, who had not been heard from in several days. Her uncle, Marvin Maddox, reported to officers that he had been told Sherbert was killed and her body was in a refrigerator in her boyfriend’s apartment. Officers went to the apartment complex, spoke with residents, and focused on Apartment 6, where Sherbert’s boyfriend, later identified as the defendant, lived. After repeated knocking and observing someone inside who did not answer the door, officers forcibly entered the apartment without a warrant. Inside, they found the defendant, two firearms, and Sherbert Maddox’s body in a refrigerator.A grand jury indicted the defendant on nine counts, including murder and firearm offenses. Before trial in the Providence County Superior Court, the defendant moved to suppress the evidence obtained from the warrantless entry, arguing it violated his constitutional rights. After a hearing, the trial justice denied the motion, finding exigent circumstances justified the entry. At trial, several counts were dismissed, and the jury convicted the defendant of second-degree murder and related firearm charges. The defendant’s motion for a new trial was denied, and he was sentenced to consecutive life terms and additional concurrent sentences. The defendant appealed, challenging the denial of his suppression motion.The Supreme Court of Rhode Island reviewed the case, applying a clearly erroneous standard to factual findings and conducting an independent review of the constitutional issues. The Court held that exigent circumstances justified the warrantless entry and search, given the urgent need to check on Sherbert Maddox’s well-being and the information available to police at the time. The Court affirmed the Superior Court’s judgment, upholding the convictions and the denial of the suppression motion. View "State v. Cooper" on Justia Law

Law enforcement officers in Montana suspected Danielle Williams of drug trafficking and observed her and Brandon Gordon engaging in suspicious activity, including Gordon climbing a fence with a black bag and entering Williams’s vehicle. After a traffic stop, officers found drug paraphernalia and two stolen handguns in the vehicle. Gordon later admitted to daily methamphetamine use and intent to use the stolen items to pay a drug debt. He was indicted for being a felon in possession of a firearm and for possessing a stolen firearm. At trial, the jury acquitted him of the stolen firearm charge but convicted him of being a felon in possession. He was sentenced to 87 months in prison.Gordon appealed his conviction to the United States Court of Appeals for the Ninth Circuit, which affirmed the conviction. He then filed a motion under 28 U.S.C. § 2255 in the United States District Court for the District of Montana, raising several claims of ineffective assistance of counsel, including that his attorney misinformed him about sentencing exposure, failed to challenge the indictment, and did not move to suppress evidence. The district court denied his claims, declined to hold an evidentiary hearing, and dismissed a second-in-time § 2255 motion as an unauthorized successive petition.The United States Court of Appeals for the Ninth Circuit reviewed the case and affirmed the district court’s denial of relief. The court held that counsel’s alleged sentencing predictions did not constitute ineffective assistance, so no evidentiary hearing was required. The court also held that, although the district court should have considered all ineffective assistance claims related to plea negotiations as a whole, Gordon’s claims failed on the merits. Finally, the court determined that Gordon’s second-in-time § 2255 motion should have been treated as a motion to amend, but denied relief because the only argument raised was foreclosed by binding precedent. The judgment was affirmed. View "USA V. GORDON" on Justia Law

After being convicted of conspiracy to distribute controlled substances, the petitioner was sentenced to 120 months in prison and five years of supervised release. While incarcerated, he participated in recidivism reduction programs and earned time credits under the First Step Act of 2018 (FSA). He continued to accrue these credits while on home confinement during the COVID-19 pandemic. Upon nearing the end of his custodial sentence, he sought to have his earned time credits applied to reduce both his remaining time in custody and the length of his supervised release. The Bureau of Prisons (BOP) applied some credits to end his custody early but refused to apply the remaining credits to reduce his supervised release, arguing that the FSA did not permit such use.The United States District Court for the Central District of California dismissed his habeas corpus petition, agreeing with the government that the FSA time credits could not be used to shorten the term of supervised release. The court found that the credits could only be applied to reduce time in custody, not supervised release, and thus denied the petitioner’s request for relief.The United States Court of Appeals for the Ninth Circuit reviewed the case de novo. The Ninth Circuit held that the plain language of the FSA, as well as relevant canons of statutory construction, demonstrate that Congress intended for earned time credits to be applied toward reducing the length of supervised release, not just custodial time. The court reversed the district court’s dismissal and remanded with instructions to grant the petition in part, direct the government to recalculate the petitioner’s earned time credits, and provide the recalculation to his probation officer. The main holding is that, under the FSA, earned time credits may be used to reduce the term of supervised release. View "GONZALEZ V. HERRERA" on Justia Law

In this case, the defendant began communicating online with an individual he believed to be a thirteen-year-old girl named Stella, who was actually an undercover police officer. Their conversations quickly became sexual, and they arranged to meet in person, at which point the defendant was arrested. After his arrest and release on pretrial supervision, the defendant deleted messages and blocked accounts of other purported minors, who were also undercover officers. Additionally, the defendant had been communicating with a real fourteen-year-old girl, Y.F., from whom he received sexually explicit images and with whom he had a prior acquaintance.The United States District Court for the District of South Dakota presided over the trial. The government introduced evidence of the defendant’s communications with other undercover accounts as Rule 404(b) evidence. The jury found the defendant guilty on all counts, including attempted sexual exploitation and enticement of a minor, and receipt of child pornography. The district court sentenced him to life imprisonment.On appeal, the United States Court of Appeals for the Eighth Circuit reviewed several issues. The court held that there was sufficient evidence for a reasonable jury to find that the defendant knew Y.F. was a minor, based on his prior relationship with her and other circumstantial evidence. The court also found that, even if the admission of the Rule 404(b) evidence was erroneous, any error was harmless given the strength of the government’s case. However, the Eighth Circuit determined that the district court may have improperly considered the trauma to the victim caused by the defendant exercising his right to trial when imposing the life sentence. As a result, the Eighth Circuit affirmed the convictions but remanded the case for resentencing. View "United States v. Barrios" on Justia Law

The case concerns a defendant who, after consuming a large quantity of alcohol over several hours at a restaurant, drove his vehicle and struck an elderly pedestrian, causing serious injuries. The defendant left the scene after briefly stopping. The incident was reported to police, and evidence, including GPS data and crash reconstruction, indicated the defendant was speeding, crossed into the opposite lane, and that his alcohol consumption contributed to the crash. Due to a delay in identifying the defendant, no chemical test of his blood-alcohol concentration (BAC) was performed at the time of the accident.The State initially charged the defendant with aggravated assault and leaving the scene of an accident involving serious bodily injury or death. A grand jury later indicted him on additional charges, including aggravated operating under the influence (OUI). The State notified the defendant that it would use expert testimony based on the Widmark formula to estimate his BAC at the time of the crash, given the absence of a chemical test. The defendant moved to exclude this testimony, but the trial court allowed the State’s chemist to testify that the defendant’s BAC exceeded .08, while prohibiting the chemist from giving an exact number or invoking statutory presumptions of intoxication. The jury found the defendant guilty on all counts, and the trial court denied his motion for acquittal.The Maine Supreme Judicial Court reviewed the case. It held that Maine’s OUI statutes do not require a chemical test as the exclusive means of proving BAC and permit the use of reliable expert opinion testimony, such as that based on the Widmark formula. The Court also found that the expert’s testimony was sufficiently tailored to the facts and thus admissible. Additionally, the Court concluded that the evidence was sufficient to support the aggravated assault conviction. The judgment was affirmed, with a remand to correct the sentencing record to reflect concurrent sentences. View "State of Maine v. MacKenzie" on Justia Law

Two individuals, referred to as Child A and Child B, alleged that Ernest Fyans sexually assaulted them in Fort Kent, Maine, between 1990 and 1992, when they were children and Fyans was an adult member of their religious congregation. Child A testified that Fyans assaulted her when she was four years old, while Child B described sexual contact beginning when she was about ten and continuing until she was thirteen. Both victims delayed reporting the abuse for many years, citing threats made by Fyans. Fyans moved out of Maine in 1992, living in Connecticut and later Massachusetts.The Aroostook County Unified Criminal Docket indicted Fyans in 2021 on one count of gross sexual assault and one count of unlawful sexual contact. At trial, both victims testified, and the State presented circumstantial evidence regarding the victims’ ages, marital status, and Fyans’s age. Fyans moved for acquittal, arguing insufficient evidence on several elements, including the statute of limitations for the unlawful sexual contact charge. The trial court denied these motions, and the jury convicted Fyans on both counts. He was sentenced to twenty years for gross sexual assault and five years, to run concurrently, for unlawful sexual contact. Fyans appealed his convictions.The Maine Supreme Judicial Court reviewed the sufficiency of the evidence and the statute of limitations issue. The Court held that there was sufficient evidence for the jury to find Fyans guilty of gross sexual assault, including the required age and marital status elements. However, the Court found insufficient evidence to support that the prosecution for unlawful sexual contact was timely, as the State failed to prove Fyans’s absence from Maine long enough to toll the statute of limitations. The Court affirmed the conviction for gross sexual assault, vacated the conviction for unlawful sexual contact, and remanded for resentencing on the remaining count. View "State of Maine v. Fyans" on Justia Law

A man was involved in an incident at a fast-food restaurant where, after displaying what appeared to be an assault rifle and making a threatening remark to a cashier, he was reported to the police. Officers located him in his car in a nearby parking lot. Believing he was armed and dangerous, police initiated a high-risk stop, ordering him to exit his vehicle. He refused repeated commands to leave the car, instead yelling at officers and behaving aggressively. Over the course of more than two hours, law enforcement—including a negotiator and SWAT team—attempted to persuade him to exit. Ultimately, officers used chemical agents and a flash device to remove him from the vehicle, where they found the rifle described by the cashier.The man was charged with several offenses, including creating a police standoff under Maine law. At trial in the Cumberland County Unified Criminal Docket, the jury heard testimony from witnesses and law enforcement. After the State rested, the defendant moved for acquittal, arguing insufficient evidence for the police standoff and criminal threatening charges. The court denied the motion. The jury found him guilty of creating a police standoff but not guilty of the other charges. He was sentenced to time already served. The defendant then filed a renewed motion for acquittal, again challenging the sufficiency of the evidence and the interpretation of the term “barricaded” in the relevant statute. The trial court denied this motion as well.On appeal, the Maine Supreme Judicial Court reviewed the statutory interpretation of “barricaded” and the sufficiency of the evidence. The Court held that the trial court correctly applied the plain meaning of “barricaded” and that sufficient evidence supported the jury’s findings on all elements of the offense. The judgment of conviction was affirmed. View "McKusick v. State of Maine" on Justia Law

A family living in Hope, Maine, who operated a medicinal marijuana cultivation business, was the victim of a violent home invasion in October 2020. Four masked intruders, some armed with a gun and a taser, broke into the home during the night, assaulted and restrained the father, threatened the family, and demanded money. The intruders also tased the family dog. During the incident, a cellphone was left behind by one of the intruders and later found by the victims. Law enforcement secured the phone, obtained its number using the emergency call function, and subsequently acquired search warrants to examine its contents and related records. DNA evidence from a mask found at the scene matched the defendant, who was later arrested and indicted on multiple charges, including robbery, assault, kidnapping, and related offenses.The Knox County Unified Criminal Docket denied the defendant’s motion to subpoena business records from the victims and his motion to suppress evidence obtained from the cellphone. The suppression court found that the defendant had no reasonable expectation of privacy in his phone number, and the trial court denied the subpoena request, finding it insufficient under the applicable rule. After a four-day jury trial, the defendant was convicted on all remaining counts, and sentenced to concurrent prison terms, with a portion suspended and probation imposed.The Maine Supreme Judicial Court reviewed the case. It held that, even assuming the detective’s use of the emergency call function on the cellphone was a search under the Fourth Amendment, the evidence was admissible under the independent source doctrine because the information was later obtained through a valid search warrant untainted by the initial action. The Court also held that the trial court did not abuse its discretion in denying the defendant’s motion to subpoena records, as the request failed to meet the required threshold for relevancy, admissibility, and specificity. The judgment was affirmed. View "State of Maine v. Carter" on Justia Law

A man was observed by a police officer in an area behind several businesses that was marked with no-trespassing signs and known for illicit drug activity. When the officer approached, the man acted suspiciously, attempted to walk away, and appeared to conceal something in his pocket. The officer, who recognized the man from previous encounters near drug houses, learned that the man was subject to bail conditions permitting searches based on articulable suspicion of drug use or possession. Upon searching him, the officer found fentanyl and cocaine, as well as drug paraphernalia and cash.The Superior Court (Penobscot County) denied the defendant’s motion to suppress the evidence, finding that the officer had reasonable suspicion to stop and search him. At trial, the court allowed expert testimony from a Maine Drug Enforcement Agency commander regarding drug prices, after offering the defense a continuance to address late disclosure, which the defense declined. The jury convicted the defendant of aggravated trafficking in fentanyl and unlawful trafficking in cocaine. The court declined to instruct the jury on unlawful possession as a lesser included offense for the fentanyl charge but did so for the cocaine charge. The defendant was sentenced to seven years (with four suspended) for aggravated trafficking, four years concurrent for cocaine trafficking, and thirty days for violating a condition of release, with forfeiture ordered.On appeal, the Maine Supreme Judicial Court affirmed the judgment. The Court held that the officer had reasonable suspicion for both the stop and the search, the trial court did not abuse its discretion in admitting the expert testimony or in its handling of the discovery issue, and any error in failing to instruct on a lesser included offense for the fentanyl charge was harmless. The Court also found no error in the sentencing analysis. View "State of Maine v. Schlosser" on Justia Law