Justia Criminal Law Opinion Summaries

Tyler Brandon Matthews was driving in Huntley, Montana, on December 30, 2019, when Corporal Bethany Richter observed several behaviors that led her to believe he was impaired. Matthews made a slow, wide turn, swerved between the center and fog lines, drove unusually slow, suddenly accelerated, and failed to maintain a consistent speed. Richter initiated a stop, resulting in Matthews's arrest and charge for driving under the influence.In Yellowstone County Justice Court, Matthews moved to suppress evidence from the stop, arguing that Richter's observations did not constitute particularized suspicion. He claimed that his driving behaviors were normal responses to road conditions. The Justice Court held an evidentiary hearing where Richter testified about her observations and training. The court viewed dash cam footage and denied Matthews's motion, concluding that Richter's training and observations provided sufficient particularized suspicion. The Thirteenth Judicial District Court affirmed this decision.The Supreme Court of the State of Montana reviewed the case, examining the Justice Court's findings of fact and application of the law. The court found that Richter's testimony and the totality of the circumstances supported particularized suspicion for the stop. The court also noted a clerical error in the written judgment, which incorrectly stated a $2,000 fine instead of the $600 fine pronounced orally. The Supreme Court affirmed the lower courts' decisions and remanded the case for correction of the written judgment to reflect the $600 fine. View "State v. Matthews" on Justia Law

In this case, the defendant, Xavier O. Maldonado-Negroni, was appealing a sentence imposed for violations of his supervised release conditions. Maldonado had a history of supervised release violations following his 2013 conviction for drug trafficking. His most recent violations included testing positive for drugs and committing domestic violence, for which he received a six-year sentence under Commonwealth law.The United States District Court for the District of Puerto Rico determined that Maldonado's violations fell within the most serious category of supervised-release violations, classified as Grade A, and sentenced him to the statutory maximum of thirty-six months' imprisonment, to run consecutively to his Commonwealth sentence. Maldonado appealed, arguing that the district court's error in classifying his violations as Grade A rather than Grade B influenced the sentencing determination.The United States Court of Appeals for the First Circuit reviewed the case and agreed with Maldonado. The court found that the district court's brief statement that it would have imposed the same sentence regardless of the violations' category was inadequate to satisfy the government's burden to show harmless error. The appellate court noted that the district court's explanation did not make clear that the erroneous Guidelines range did not influence the sentence. Consequently, the First Circuit vacated the sentence and remanded the case for resentencing, emphasizing the need for a clear and unmistakable record that the Guidelines error did not affect the sentencing decision. View "United States v. Maldonado-Negroni" on Justia Law

In 1999, a jury convicted Patrick Allen Trent of first-degree murder and street terrorism but found not true the enhancements that he had personally used a knife and that the murder was committed for the benefit of a criminal street gang. The trial court sentenced him to 25 years to life plus eight months. This court affirmed the judgment in 2001. Trent’s first-degree murder conviction was later reduced to second-degree murder, reducing his aggregate term to 15 years to life plus eight months. In July 2020, Trent filed a petition for resentencing under former section 1170.95, which the trial court granted in February 2022. The trial court redesignated the murder conviction as assault with force likely to cause great bodily injury with a great bodily injury enhancement and resentenced Trent to six years eight months.The trial court denied Trent’s request to vacate the gang conviction, finding that section 1172.6 concerned the murder conviction. Trent timely appealed, arguing that the trial court erred in failing to retroactively apply Assembly Bill No. 333 to his gang conviction and in imposing a great bodily injury enhancement to the redesignated offense. The People opposed Trent’s arguments but agreed that the abstract of judgment required correction to reflect that Trent’s convictions were by jury, not by plea.The California Court of Appeal, Third Appellate District, agreed with Trent that he was entitled to the retroactive application of Assembly Bill No. 333, requiring the reversal of his section 186.22 conviction and remand for further proceedings. The court also vacated Trent’s great bodily injury enhancement, finding that the trial court erred in imposing an uncharged enhancement. The court directed the trial court to prepare an amended abstract of judgment reflecting these changes and that Trent’s convictions were by jury. The judgment was otherwise affirmed. View "P. v. Trent" on Justia Law

James Dixon was convicted in 2008 of first-degree murder and two counts of rape. The jury found true special-circumstance allegations that the murder was committed during a robbery and kidnapping, and Dixon was sentenced to death. Additionally, the court imposed and stayed execution of two consecutive terms of 25 years to life for the rape convictions, a one-year firearm enhancement, and four one-year prior prison term enhancements under Penal Code section 667.5, former subdivision (b).The Department of Corrections and Rehabilitation informed the Superior Court of Los Angeles County in 2023 that Dixon was eligible for recall and resentencing under section 1172.75. The superior court, without holding a hearing, permanently stayed execution of the prior prison term enhancements but ruled Dixon was not eligible for resentencing because the trial court had stayed execution of his enhancements. Dixon appealed, arguing he was entitled to a full resentencing.The California Court of Appeal, Second Appellate District, Division Seven, reviewed the case. The court concluded that the superior court had jurisdiction to resentence Dixon on the noncapital portions of his sentence, despite his pending automatic appeal in the Supreme Court. The court held that section 1172.75 applies to all enhancements imposed under section 667.5, former subdivision (b), whether executed or stayed. Therefore, the superior court should have stricken the prior prison term enhancements and conducted a resentencing hearing on the non-death portions of Dixon’s sentence.The Court of Appeal reversed the superior court's order and directed it to vacate its previous order, strike Dixon’s prior prison term enhancements, and resentence him on the rape convictions and the firearm enhancement in accordance with section 1172.75. The superior court was also instructed to prepare a new abstract of judgment and send it to the Department. View "P. v. Dixon" on Justia Law

Duane Berry was indicted in 2015 for planting a fake bomb outside a building in Detroit. The district court in Michigan found him mentally incompetent to stand trial and committed him to the custody of the Attorney General under 18 U.S.C. § 4241 for a competency evaluation. After determining that his competency could not be restored, the court dismissed the charges against him in December 2019. Concerned about his potential danger to the public, the court ordered a psychological evaluation under 18 U.S.C. § 4246.The government faced delays due to a backlog at the evaluation facility and the COVID-19 pandemic. Berry was eventually evaluated, and the facility's director certified that his release would pose a substantial risk. The United States District Court for the Eastern District of North Carolina held a hearing and found by clear and convincing evidence that Berry met the criteria for commitment under § 4246, as he was still in custody under § 4241 when the certification was filed.Berry appealed, arguing that he did not fall into any of the categories eligible for commitment under § 4246 and that the delay in filing the certification was unreasonable. The United States Court of Appeals for the Fourth Circuit reviewed the case and concluded that Berry was in lawful custody under § 4241 at the time of the certification. The court found the delay reasonable given the administrative challenges and the pandemic. The Fourth Circuit affirmed the district court's decision to commit Berry under § 4246, holding that the statutory provisions were followed correctly and that Berry's continued custody was lawful. View "United States v. Berry" on Justia Law

The defendant was convicted of felony murder and attempted robbery in the first degree, among other charges, following an incident where another individual, Christian, shot and killed the victim, Rodney, during a scuffle that ensued after the defendant attempted to rob Rivera. The defendant appealed, arguing that the state needed to prove that Christian was an accessory to the attempted robbery to secure a felony murder conviction.The trial court had instructed the jury on the felony murder statute, which does not require the state to prove that a participant in the crime was an accessory. The defendant was found guilty of felony murder, attempted robbery, and firearm offenses, but not guilty of murder as an accessory. The trial court vacated the manslaughter conviction on double jeopardy grounds and sentenced the defendant to forty years in prison.The Connecticut Supreme Court reviewed the case and held that the felony murder statute does not require the state to establish that a participant who caused the death was an accessory to the predicate felony. The court found sufficient evidence to support the conviction, noting that Christian's actions were in furtherance of the attempted robbery and that the killing occurred during the continuous sequence of events surrounding the attempted robbery.The court also rejected the defendant's claim of instructional error, as the trial court's instructions were legally proper and did not need to include a requirement for proving accessorial liability. Additionally, the court found that the defendant had waived his confrontation clause claim by not objecting to the admission of Rivera's video-recorded interviews at trial.Finally, the court declined to overrule its precedent in State v. Newsome, which allows a reliable out-of-court statement to serve as the sole evidentiary basis for a conviction. The court concluded that Rivera's statements were reliable and corroborated by other evidence, thus sufficient to establish the defendant's intent to commit attempted robbery.The judgment of the trial court was affirmed. View "State v. Hinton" on Justia Law

Deshawn Lynn Randolph was charged with two counts of soliciting for child prostitution under Colorado law. The charges stemmed from interactions with an undercover investigator posing as a minor on a social networking platform. Randolph offered to arrange sex work for the investigator, who had claimed to be underage. At trial, Randolph argued that he did not intend to arrange sex work but was merely boasting to delay any action until the investigator turned eighteen.The district court instructed the jury that the applicable mental state for the charges was "knowingly," rejecting Randolph's proposed instruction that would have required proof of "intentionally." The jury found Randolph guilty, and he was sentenced to two concurrent nine-year terms. Randolph appealed, arguing that the jury instructions were incorrect. The Colorado Court of Appeals affirmed the convictions, holding that "knowingly" was the correct mental state.The Supreme Court of Colorado reviewed the case to resolve the appropriate mental state for the crime of soliciting for child prostitution. The court held that the culpable mental state for the crime under subsections (1)(a) and (1)(b) of the statute is "knowingly," aligning with the mental state explicitly designated in subsection (1)(c). The court affirmed the lower court's judgment, concluding that the district court did not err in its jury instructions. View "Randolph v. People" on Justia Law

In 2008, Kelly James Schnorenberg formed KJS Marketing, Inc. to secure funding and recruit agents for insurance companies. Between 2009 and 2015, KJS solicited over $15 million from approximately 250 investors, promising a 12% annual return. Schnorenberg failed to disclose to investors his past legal and financial troubles, including a lawsuit by the Colorado Division of Securities, a permanent injunction from selling securities in Colorado, a bankruptcy filing, and unpaid civil judgments.Schnorenberg was charged with twenty-five counts of securities fraud under section 11-51-501, with twenty-four counts based on materially false statements or omissions and one count based on a fraudulent course of business. He planned to defend himself by arguing that he acted in good faith reliance on the advice of his securities lawyer, Hank Schlueter. However, the trial court denied his motions for a continuance to secure Schlueter's testimony and excluded Schnorenberg's testimony about the specific advice he received, ruling it as hearsay.The Colorado Court of Appeals vacated seven of Schnorenberg's convictions as time-barred, reversed the remaining convictions, and remanded the case for further proceedings. The court concluded that the trial court erred in excluding Schnorenberg's testimony about his lawyer's advice and in not instructing the jury that good faith reliance on the advice of counsel could negate the mens rea element of the securities fraud charges.The Supreme Court of Colorado reviewed the case and held that the mens rea of "willfully," synonymous with "knowingly," applies to each element of securities fraud under subsections 11-51-501(1)(b) and (c). The court concluded that Schnorenberg's testimony about his lawyer's advice was relevant to whether he had the requisite mens rea and that the trial court erred in excluding this testimony. The court affirmed the judgment of the Court of Appeals and remanded the case for a new trial. View "People v. Schnorenberg" on Justia Law

Evelio Santana pleaded guilty to unlawful possession of a firearm as a convicted felon. His sentence was enhanced under the Armed Career Criminal Act (ACCA) after the district judge found by a preponderance of the evidence that Santana had three prior convictions for violent felonies committed on different occasions. Santana appealed, arguing that the determination should have been made by a jury beyond a reasonable doubt, as required by a recent Supreme Court decision in Erlinger v. United States.The United States District Court for the Southern District of Indiana initially handled Santana's case. The district judge determined that Santana's prior convictions were committed on different occasions and sentenced him to the mandatory minimum of fifteen years in prison under the ACCA. Santana's lawyer had agreed with the judge's authority to make this determination based on then-current Seventh Circuit precedent. The government objected, arguing that a jury should make the determination, but the judge overruled the objection.The United States Court of Appeals for the Seventh Circuit reviewed the case. The court found that an error occurred because the judge, not a jury, made the different-occasions determination by a preponderance of the evidence, contrary to the Supreme Court's ruling in Erlinger. The error was plain and affected Santana's substantial rights by increasing his sentence. The court concluded that the error undermined the fairness and integrity of the proceedings, as a reasonable jury might have found reasonable doubt about whether the prior felonies were committed on different occasions. Consequently, the Seventh Circuit vacated Santana's sentence and remanded the case for resentencing consistent with the Supreme Court's decision in Erlinger. View "United States v Santana" on Justia Law

Kenneth Alfonso Gallegos and three friends attempted to obtain vaping products from a high school classmate, L.C. During the encounter, a struggle ensued, and one of Gallegos's friends fatally shot L.C. Gallegos was charged with felony murder, with predicate felonies of aggravated robbery, attempted robbery, and conspiracy to commit aggravated robbery. At trial, Gallegos denied planning to rob L.C. or knowing about the gun. He requested a jury instruction on the affirmative defense to felony murder, which the trial court denied, deeming it incompatible with his outright denial of involvement in the crime.The jury found Gallegos guilty, and he appealed. The Colorado Court of Appeals reversed his felony murder conviction, holding that defendants may both deny the predicate felony and raise the affirmative defense to felony murder. The court found that the trial court erred by not giving Gallegos's requested instruction.The Supreme Court of Colorado reviewed the case and held that a defendant need not admit the predicate felony to raise the affirmative defense to felony murder. The court affirmed the judgment of the court of appeals, concluding that the plain language of the affirmative defense statute does not require an admission of the underlying felony. The court emphasized that the affirmative defense to felony murder can be raised even if the defendant denies committing the predicate felony, as long as there is some credible evidence supporting the defense's conditions. View "People v. Gallegos" on Justia Law