Justia Criminal Law Opinion Summaries

The case involved a fatal shooting that followed a car accident in Hartford, Connecticut. The defendant, after colliding with the victim’s vehicle, agreed to pay for the damages and arranged to meet the victim later that day. Surveillance footage and eyewitness accounts linked the defendant to the scene, describing his distinctive clothing and actions. Evidence showed the defendant met with the victim, shot him multiple times, and fled the scene. Forensic analysis detected gunshot residue on the defendant’s clothing, and cellphone data further corroborated his involvement. The defendant was subsequently arrested and charged with murder and criminal possession of a firearm.At trial in the Superior Court for the judicial district of Hartford, the jury found the defendant guilty of murder, and the court found him guilty of criminal possession of a firearm. The defendant appealed directly to the Connecticut Supreme Court, raising several unpreserved constitutional claims. He argued that his right to confrontation was violated when the State’s gunshot residue expert testified based on data and notes from a nontestifying analyst, and when the prosecutor elicited testimonial hearsay on cross-examination. He also alleged prosecutorial impropriety for introducing facts not in evidence during cross-examination.The Connecticut Supreme Court held that the claim regarding the expert’s reliance on the nontestifying analyst’s materials failed because the record was inadequate to determine whether those materials were testimonial. The court declined to adopt the State’s proposed rule barring all unpreserved confrontation claims and reaffirmed that such claims may still be reviewed if the record is sufficient. The court further held there was no confrontation clause violation or prosecutorial impropriety regarding the cross-examination, as the questions did not introduce hearsay or inadmissible evidence. The judgment of conviction was affirmed. View "State of Connecticut v. Bester" on Justia Law

A five-year-old child and her mother, recently arrived from the Dominican Republic, were staying with family in New Britain, Connecticut. The defendant, who was married to the mother's niece, lived in the same apartment. On New Year's Eve, the defendant sexually assaulted the child. Later that evening at a family party, the child told her mother that the defendant had kissed her, and after further questioning, disclosed more details of the assault. The next day, the mother confronted the defendant, who made incriminating admissions both in person and via text. Police interviewed the defendant at the station after he voluntarily agreed to meet and requested a Spanish-speaking detective. During the interview, which was conversational and not confrontational, the defendant confessed to inappropriate sexual conduct.The Superior Court, Judicial District of New Britain, denied the defendant’s pretrial motion to suppress his statements to police, finding he was not in custody for Miranda purposes. At trial, the court admitted the child’s statements to her mother under the spontaneous utterance exception to hearsay, and limited the testimony of the defense expert regarding the U visa program, which provides immigration benefits to victims of certain crimes who cooperate with law enforcement. The jury convicted the defendant of sexual assault in the first degree and risk of injury to a child.On direct appeal to the Connecticut Supreme Court, the defendant argued the trial court erred in denying his suppression motion, admitting the victim’s hearsay statements, and restricting expert testimony, and further sought review of confidential personnel records of one detective. The Connecticut Supreme Court held that the trial court properly denied the suppression motion, as the defendant was not in custody. The admission of the child’s statements was error but harmless, given other strong evidence. The limitations on the expert’s testimony did not deny due process or affect the verdict. Review of the confidential records revealed no material requiring disclosure. The conviction was affirmed. View "State of Connecticut v. Lazaro D." on Justia Law

On November 23, 2019, the appellant was driving an Acura with three children, including her own, when her vehicle was rear-ended by another driver. Witnesses testified that after this collision, the Acura accelerated rapidly, left the road, then reentered it and collided head-on with a Yukon. The crash resulted in the death of one child and serious injury to another. At the time, the appellant’s driver’s license was suspended, and she was not permitted unsupervised contact with her children due to prior involvement with Child Protective Services.The State of Montana charged the appellant with multiple offenses, including negligent homicide, criminal endangerment, and driving with a suspended license. The Thirteenth Judicial District Court, Yellowstone County, presided over a six-day jury trial. The jury found the appellant guilty on all counts. The appellant’s defense argued that the initial rear-end collision was the cause of the subsequent crash, while the prosecution maintained that the appellant’s actions, including improperly restraining the children and fleeing the scene, were negligent and directly led to the fatal incident.On appeal to the Supreme Court of the State of Montana, the appellant challenged the sufficiency of the evidence for the negligent homicide conviction, asserted ineffective assistance of counsel, objected to the admission of certain expert testimony, sought a mistrial based on inadmissible testimony, and disputed the order of restitution for lost wages. The Montana Supreme Court affirmed the District Court’s judgment. It held that there was sufficient evidence for the negligent homicide conviction, found no ineffective assistance of counsel, ruled that the District Court did not abuse its discretion in admitting expert testimony or denying a mistrial, and upheld the restitution award, finding it legally appropriate under Montana law. View "State v. Mullendore" on Justia Law

The case concerns a confrontation between the defendant, a 29-year-old man, and his 79-year-old neighbor in Winnett, Montana. After an altercation outside their apartments, the neighbor was found fatally stabbed, while the defendant had a gunshot wound. The defendant claimed he acted in self-defense after the neighbor allegedly shot him first. Physical evidence, however, contradicted the defendant’s account, indicating the victim was not standing when stabbed and that the sequence of events differed from the defendant’s narrative. The defendant was charged with deliberate homicide, with a sentencing enhancement for use of a dangerous weapon.In the Tenth Judicial District Court, the defendant initially indicated he might raise a mental disease or disorder defense but failed to meet several disclosure deadlines and ultimately abandoned that defense. The District Court, upon a motion in limine by the State, precluded the defendant from introducing evidence to support a lesser-included offense of mitigated deliberate homicide while pursuing a justifiable use of force (self-defense) claim. The court also addressed juror evidentiary questions during trial without consulting the parties, to which the defendant did not object. After a jury trial, the defendant was convicted and sentenced to 110 years in prison.On appeal, the Supreme Court of the State of Montana found that the District Court erred in categorically precluding the defendant from seeking a mitigated deliberate homicide instruction while pursuing a justifiable use of force defense. The Supreme Court clarified that a defendant may present alternative theories if supported by the evidence. However, the Supreme Court affirmed the conviction, holding that the defendant failed to show he was prejudiced, as he did not present admissible evidence supporting mitigation at trial. The court also declined to exercise plain error review regarding the handling of juror questions, finding no manifest miscarriage of justice. The judgment was affirmed. View "State v. Smith" on Justia Law

In this case, the defendant was charged in October 2022 with possession of child pornography, including an enhancement for possessing a large number of images involving very young minors. In February 2023, he pleaded guilty and was sentenced to probation, jail time under work release, and required to register as a sex offender. The defendant is a registered nurse, and after his conviction, the state Board of Registered Nursing began disciplinary proceedings to remove his license. He lost his job but later received support from his former employer and sought therapy and treatment.In September 2023, the defendant petitioned the Superior Court of Riverside County under Penal Code section 236.15 to vacate his conviction. He argued that his offense was a direct result of sexual violence he suffered as both a child and an adult, including repeated abuse and rapes. The petition was supported by a clinical director who opined that the defendant’s behavior was a “direct result” of trauma repetition linked to his history of sexual violence. After an evidentiary hearing in January 2024, the Superior Court granted the petition and vacated the conviction, leading to the dismissal of disciplinary proceedings against him.The California Court of Appeal, Fourth Appellate District, Division Two, reviewed the case. The court clarified the requirements for relief under section 236.15 and held that the abuse of discretion standard applies to appellate review. It found that, although the defendant suffered significant sexual violence, his later possession of child pornography was not a “direct result” of that victimization as required by the statute. The court emphasized that multiple contributing factors and the passage of time attenuated the causal connection. The appellate court reversed the trial court’s order granting the petition and directed the lower court to deny the petition. View "P. v. S.H." on Justia Law

Robdarius Williams participated in the robbery of an AT&T store, during which a confederate brandished a rifle at a store employee. Prior to the robbery, law enforcement, as part of an ongoing investigation, installed a GPS tracker on a car registered to Williams’s mother. Surveillance revealed Williams driving the car to pick up his accomplices, including Quintez Tucker, who was seen with a rifle. The group switched license plates and circled a shopping center before Tucker and another man entered the AT&T store, with one carrying the rifle visibly concealed. Inside, the rifle was displayed and pointed at an employee, and instructions were given via speakerphone by someone with a deep voice, which matched Williams’s description. The robbers fled in Williams’s car and were later apprehended.The United States District Court for the Southern District of Indiana tried Williams on charges of Hobbs Act robbery and aiding and abetting the brandishing of a firearm during a crime of violence. A jury convicted Williams on both counts. The district court sentenced him to a total of 114 months, including the mandatory minimum for brandishing. Williams did not move for a judgment of acquittal at trial.On appeal to the United States Court of Appeals for the Seventh Circuit, Williams challenged the sufficiency of the evidence for the aiding and abetting brandishing conviction, arguing the government failed to prove he had advance knowledge that the rifle would be brandished. Applying the plain error standard due to Williams’s failure to seek acquittal below, the Seventh Circuit held that the evidence was sufficient for a rational jury to conclude Williams had the requisite advance knowledge. The court affirmed the conviction, finding no manifest miscarriage of justice. View "USA v Williams" on Justia Law

An employee was hired by a nonprofit organization to help organize a fundraiser and was given access to a board member’s email account for work purposes. After a dispute about the nature of her employment, the employee resigned and requested payment for her services, but the organization stopped communicating with her and did not pay. The former employee, still having technical access to the email account, began accessing it, downloaded internal documents, and sent them to a friend. The friend subsequently threatened the organization with releasing these documents unless both were paid substantial sums. The organization eventually revoked the employee’s access and reported the matter to the authorities.A grand jury in the United States District Court for the Eastern District of Pennsylvania indicted both individuals on several counts of violating the Computer Fraud and Abuse Act (CFAA), which prohibits intentionally accessing a computer “without authorization.” At trial, the prosecution’s theory was that the employee’s resignation automatically ended her authorization to access the email account, making her subsequent access a crime. The district court denied defense motions for acquittal and a new trial, the latter of which challenged both the jury instructions on authorization and the prosecutor’s remarks about extortion.The United States Court of Appeals for the Third Circuit held that, in the absence of any evidence the organization took affirmative steps to revoke the employee’s authorization—or any contract linking authorization to employment—the mere act of resignation did not terminate authorization under the CFAA. The court found the jury instruction on authorization erroneous and determined there was insufficient evidence to support the conviction. The Third Circuit vacated the conviction and ordered a judgment of acquittal. The court also found that any improper remarks by the prosecutor were harmless given the curative instructions. View "USA v. Eddings" on Justia Law

A man living in Muskogee, Oklahoma, fatally shot his neighbor after developing the belief that the neighbor had harmed his daughter, despite no history of conflict or any evidence supporting this belief. The shooter had been prescribed unusually high doses of Adderall, and a Bureau of Prisons psychologist concluded that he suffered from amphetamine-induced psychosis at the time of the shooting. At trial, the defendant admitted to the killing but raised the affirmative defense of involuntary intoxication due to his prescribed medication, asserting he could not appreciate the wrongfulness of his actions. Both parties presented expert and lay testimony regarding the defendant’s mental state and drug use, including the possibility of methamphetamine use.The United States District Court for the Eastern District of Oklahoma presided over a jury trial. The court instructed the jury on involuntary intoxication but included categorical disqualifiers: the jury was told that the defense could not apply if the defendant had knowledge of Adderall’s possible intoxicating effects, or if he had used illegal drugs while on Adderall. The court also denied the defense’s request for an instruction on involuntary manslaughter based on “imperfect defense of another.” The jury rejected the involuntary intoxication defense and convicted the defendant of first-degree murder and related firearm offenses.On appeal, the United States Court of Appeals for the Tenth Circuit held that the district court’s jury instructions on involuntary intoxication were legally erroneous. Specifically, the Tenth Circuit found it was improper to instruct the jury that any knowledge of possible intoxicating effects, or any illegal drug use while taking Adderall, categorically barred the defense. The court reversed the conviction and remanded for a new trial, holding that the errors were not harmless. The Tenth Circuit also concluded the district court erred by failing to give the requested imperfect defense of another instruction, which may be relevant at retrial. View "United States v. Rainford" on Justia Law

The appellant was charged with several serious offenses after allegedly shooting a neighbor during a dispute at their apartment complex. The evidence included eyewitness testimony, gunshot residue on the appellant’s hands, and ammunition found in the appellant’s apartment matching shell casings at the scene. The appellant ultimately entered a no-contest plea to reduced charges, but later sought to withdraw the plea, claiming that his attorney’s actions led him to enter the agreement involuntarily and without full understanding of the case against him.After the appellant attempted to file a pro se motion to withdraw his plea, his defense counsel followed guidance from a prior decision (Reed v. State) by moving to withdraw as counsel and requesting substitute counsel. The Superior Court of the State of Delaware held a hearing, but did not first address the motion to withdraw as counsel. Instead, the court required the appellant to advocate for his own plea withdrawal and ultimately granted the motion to withdraw the plea, finding it had not been entered voluntarily. However, the court denied counsel’s motion to withdraw and required the same attorney to represent the appellant at trial, where he was convicted by a jury and sentenced to prison.On appeal, the Supreme Court of the State of Delaware held that when defense counsel moves to withdraw after a defendant expresses a desire to withdraw a plea, the trial court must first address and resolve the motion to withdraw as counsel, applying the established “good cause” standard. The failure to do so in this case resulted in the defendant being denied his constitutional right to counsel at a critical stage. The Supreme Court reversed the appellant’s convictions and remanded for further proceedings consistent with its opinion. View "Bolden v. State" on Justia Law

The petitioner was convicted following a jury trial for filing a fraudulent tax return and theft of government funds, after he submitted a tax form claiming a large refund based on a mistaken belief about a government “trust” linked to Social Security. He received and spent the refund, then requested another, which was denied. The IRS investigated, and he later filed a document stating he was deceased. His defense at trial centered on his claim that he misunderstood tax law due to information from an online forum and advice from an IRS agent.The United States District Court for the Northern District of Indiana oversaw the criminal trial, where the petitioner was represented by attorney John Davis. During trial, Davis pursued motions under Brady v. Maryland, seeking exculpatory evidence, but the motions were denied. After conviction, Davis was removed from the Seventh Circuit Bar for misconduct in an unrelated case. The petitioner then moved for a new trial and, later, for relief under 28 U.S.C. § 2255, arguing ineffective assistance of counsel based on Davis’s disciplinary history and alleged trial errors. The district court denied both motions, finding Davis’s performance did not prejudice the petitioner’s defense and that his disciplinary issues in other cases did not establish ineffectiveness in the present case.On appeal, the United States Court of Appeals for the Seventh Circuit reviewed the district court’s denial of collateral relief de novo for legal issues and for clear error regarding factual findings. The court held that there is no per se rule that concurrent or subsequent attorney discipline renders counsel ineffective; instead, a petitioner must show specific deficient performance and resulting prejudice under Strickland v. Washington. The petitioner failed to demonstrate that counsel’s alleged errors affected the outcome of the trial. The Seventh Circuit affirmed the district court’s denial of the § 2255 motion. View "Blake v USA" on Justia Law