Justia Criminal Law Opinion Summaries

Alexander Olson was involved in a conspiracy with seven others to set fires in four Walmart stores in Alabama and Mississippi during business hours. The fires caused chaos, fear, and significant property damage. Olson was indicted on two counts of maliciously setting fires and one count of conspiracy to do so. He pleaded guilty to the conspiracy charge in exchange for the dismissal of the other charges and a recommended sentence of 60 months imprisonment.The United States District Court for the Southern District of Alabama accepted Olson's guilty plea but did not follow the government's sentencing recommendation. Instead, the court sentenced Olson to 180 months imprisonment, three years of supervised release, and ordered him to pay over $7 million in restitution. The court justified the higher sentence by citing the extensive property damage, the risk to human life, and the political motivation behind the fires.Olson appealed to the United States Court of Appeals for the Eleventh Circuit, arguing that the district court erred by not clearly specifying whether the sentence was a result of a departure or a variance and that the sentence was substantively unreasonable. The Eleventh Circuit found that the district court's statement that it would have imposed the same sentence "whether an upward departure or a variance" rendered the distinction irrelevant. The appellate court also held that the sentence was substantively reasonable given the severity of the offenses and the factors considered by the district court.The Eleventh Circuit affirmed the district court's decision, concluding that there was no abuse of discretion in the sentencing. View "USA v. Alexander Olson" on Justia Law

The defendant, a police captain in the West Springfield police department, was found guilty of obtaining an unwarranted privilege with fraudulent intent by using over $1,000 from the police department's evidence room to pay his home mortgage. The defendant was sentenced to a one-year term of probation. He appealed his conviction on the grounds that the statutes under which he was convicted were unconstitutionally vague and that the evidence was insufficient to prove he acted with fraudulent intent or that the unwarranted privilege had a fair market value of over $1,000 in any twelve-month period.The Superior Court denied the defendant's pretrial motion to dismiss the indictment. After a jury-waived trial, the trial judge found the defendant guilty and denied his motion for a required finding of not guilty. The defendant then appealed to the Supreme Judicial Court of Massachusetts.The Supreme Judicial Court affirmed the conviction, holding that the statutes in question were not unconstitutionally vague. The court found that the terms "unwarranted privilege" and "fraudulent intent" provided sufficient notice of prohibited conduct to a person of reasonable intelligence. The court also concluded that the evidence was sufficient to prove the defendant acted with fraudulent intent, as he had secreted money from the evidence room to pay his mortgage and made false statements to investigators. Additionally, the court determined that the fair market value of the unwarranted privilege exceeded $1,000, based on the face value of the money taken from the evidence room. View "Commonwealth v. Spaulding" on Justia Law

In 2018, Kevin Hoff pled guilty to murder and was sentenced to life without parole. Since his conviction, Hoff has filed three applications for postconviction relief. His first application, filed in May 2020, claimed ineffective assistance of counsel and newly discovered evidence. The amended application, which abandoned the newly discovered evidence claim, was denied, and the denial was affirmed on appeal. Hoff's second application, filed in December 2021, claimed his trial counsel incorrectly advised him about the defense of others. The State moved to dismiss this application as time-barred and for summary disposition based on res judicata and misuse of process. The district court granted the State's motions, and Hoff did not appeal.In his third application, Hoff claimed a mental disease excepted him from the two-year limitation, his trial counsel incorrectly advised him, and newly discovered evidence existed. He also filed a Rule 60(b) motion to vacate the order denying his second application. The district court consolidated the Rule 60(b) motion with the third application and held an evidentiary hearing. The court granted the State's motion to dismiss based on the two-year limitation, granted the State's motion for summary disposition based on res judicata and misuse of process, denied Hoff's application, and dismissed his Rule 60(b) motion.The North Dakota Supreme Court reviewed the case and affirmed the district court's judgment. The court held that Hoff's third application was barred by the two-year limitation in N.D.C.C. § 29-32.1-01(2) and that Hoff did not demonstrate a physical disability or mental disease that precluded timely assertion of his application. The court also concluded that Hoff waived the issue of the denial of his Rule 60(b) motion by not adequately briefing it on appeal. The court did not address the res judicata and misuse of process arguments, as the application was already precluded by the two-year limitation. View "Hoff v. State" on Justia Law

Richard W. Kelley was convicted of aggravated trafficking of scheduled drugs after a stop and search of a friend's vehicle in which he was a passenger. Law enforcement conducted the search as part of an investigation into the vehicle's owner for drug trafficking, using a search warrant and two tracking warrants to monitor the vehicle's location. Kelley moved to suppress the evidence obtained through the warrants, arguing that he had a reasonable expectation of privacy in the vehicle.The trial court (Penobscot County, A. Murray, J.) denied Kelley's motion to suppress on the grounds that he lacked standing to challenge the search. Kelley argued that the court should not have addressed his standing because the State had stipulated that he had a reasonable expectation of privacy in the vehicle. However, the court concluded that standing is a threshold issue that must be addressed regardless of the State's stipulation. Kelley was subsequently convicted based on his conditional guilty plea.The Maine Supreme Judicial Court reviewed the case and affirmed the trial court's decision. The court held that the State's stipulation regarding Kelley's standing was not binding on the court. The court further held that Kelley lacked a reasonable expectation of privacy in the vehicle, as he did not have a property or possessory interest in it, nor did he have an interest in the property seized. Therefore, Kelley did not have standing to challenge the search warrants. The judgment of conviction was affirmed. View "State of Maine v. Kelley" on Justia Law

Jarvis Mikel Jackson pled guilty to possession of a firearm as a felon, violating 18 U.S.C. § 922(g)(1). The district court calculated an advisory Sentencing Guidelines range of 110 to 120 months and sentenced Jackson to 115 months in prison. Jackson appealed, arguing that the district court erred in treating his two prior South Carolina drug distribution convictions as "controlled substance offenses" under the Guidelines, which increased his base offense level.Initially, the district court overruled Jackson's objection, distinguishing the South Carolina statute from the West Virginia statute in United States v. Campbell, which did not qualify as a controlled substance offense. The district court adopted the PSR's base offense level and sentenced Jackson to 115 months. Jackson appealed, and the Fourth Circuit vacated his sentence, agreeing that the South Carolina statute included attempted deliveries, making it broader than the Guidelines definition.Before Jackson's resentencing, the Fourth Circuit issued decisions in United States v. Groves and United States v. Davis. Groves held that a federal drug distribution conviction is a controlled substance offense under the Guidelines, while Davis held that South Carolina's statute is materially distinguishable from West Virginia's and qualifies as a controlled substance offense. At resentencing, the district court followed Davis, overruled Jackson's objection, and again sentenced him to 115 months without addressing his arguments for a downward variance based on post-sentencing conduct.The United States Court of Appeals for the Fourth Circuit reviewed Jackson's appeal, agreeing with the district court's reliance on Davis but finding procedural error in the lack of individualized explanation for the sentence. The court vacated Jackson's sentence and remanded for resentencing, requiring the district court to address Jackson's arguments and provide an adequate explanation for the sentence. View "United States v. Jackson" on Justia Law

Andre Lester was charged and convicted of multiple sex offenses with a minor. At trial, the State presented Verizon phone records to link Lester to the crimes. Exhibit #2 showed the time, date, and connecting number for every call made to or from the phone allegedly belonging to Lester. Exhibit #3 featured a subset of that data, showing communications between Lester’s phone and the victim’s phone. Lester argued that the admission of these exhibits violated the Confrontation Clause and hearsay rules because he could not cross-examine the source of the data.The Superior Court of Wake County admitted the exhibits under Rule 803(24), the catch-all hearsay exception, despite acknowledging that they did not meet the business records exception under Rule 803(6). The jury convicted Lester on all counts, and he appealed. The Court of Appeals reversed the convictions, holding that the admission of the exhibits violated the Confrontation Clause and hearsay rules, and ordered a new trial.The Supreme Court of North Carolina reviewed the case and found that the Court of Appeals misapplied the Confrontation Clause analysis. The Supreme Court held that machine-generated raw data, if truly machine-generated, are neither hearsay nor testimonial under the Confrontation Clause. The Court emphasized that the primary purpose test should focus on why the data were created, not why they were later retrieved. The Court concluded that if Verizon’s systems recorded the data as part of routine operations, the data were not created for use in a trial. The Supreme Court reversed the decision of the Court of Appeals and remanded the case for consideration of Lester’s remaining issues. View "State v. Lester" on Justia Law

In August 1998, a 17-year-old defendant, a member of the Crips gang, participated in the abduction, robbery, and murder of three women, resulting in the death of two and the attempted murder of the third. The defendant was arrested and indicted on multiple charges, including two counts of first-degree murder. In 2000, a jury found him guilty, and he was sentenced to death. The North Carolina Supreme Court vacated the death sentence due to a jury polling error and remanded for resentencing. Following the U.S. Supreme Court's ruling in Roper v. Simmons, which prohibited the death penalty for juveniles, the defendant was resentenced to life without parole.The trial court later resentenced the defendant under a new statutory scheme following the U.S. Supreme Court's decision in Miller v. Alabama, which prohibited mandatory life without parole for juveniles. The trial court considered mitigating factors and sentenced the defendant to two consecutive life without parole terms, finding him irreparably corrupt. The defendant appealed, arguing that his sentences violated the Eighth Amendment and the North Carolina Constitution.The North Carolina Court of Appeals affirmed the sentences, finding that the trial court properly considered all mitigating factors and that the sentences complied with both federal and state constitutional requirements. The court rejected the defendant's argument that his sentences were unconstitutional per se and found that the evidence supported the trial court's conclusion of irreparable corruption.The North Carolina Supreme Court reviewed the case and affirmed the Court of Appeals' decision. The court held that the state constitution's prohibition on cruel or unusual punishments does not provide broader protections than the Eighth Amendment. The court also found that the trial court's resentencing did not violate the principles established in State v. Kelliher. View "State v. Tirado" on Justia Law

Robert Lee Harris Jr. was convicted by a jury of first-degree premeditated murder of his wife. On appeal, Harris challenged the district court's denial of his motion to suppress evidence obtained from his locked cell phones. He argued that law enforcement obtained the passcodes to unlock the phones in violation of his Fifth Amendment privilege against self-incrimination.The Johnson District Court found that Harris voluntarily disclosed the passcodes, knowing the incriminating information they might yield. The court concluded that the initial Miranda warning given to Harris was still effective, and his prior Miranda waiver had not expired when the detective asked him to provide the passcodes. The court also found that the detective's statement about obtaining a court order to compel fingerprint access or the passcodes was not inherently coercive, as the detective had a reasonable basis to believe a court would issue such an order.The Kansas Supreme Court reviewed the case and affirmed the district court's decision. The court held that substantial competent evidence supported the district court's finding that Harris' disclosure of the passcodes was voluntary and not obtained in violation of his Fifth Amendment rights. The court concluded that the initial Miranda warning and Harris' waiver were still valid at the time of the second interrogation, so a renewed Miranda warning was not necessary. Additionally, the court found that the detective's statement about obtaining a court order was not inherently coercive and that Harris provided the passcodes voluntarily, considering the totality of the circumstances. Therefore, the district court did not err in denying Harris' motion to suppress the evidence obtained from the cell phones. View "State v. Harris" on Justia Law

Deshonte Antwon Dickson was charged with conspiracy to distribute heroin and methamphetamine. At his trial, witnesses testified that Dickson supplied methamphetamine and heroin from California to North Dakota. The jury convicted him of conspiring to distribute heroin and between 50 and 500 grams of methamphetamine. The Presentence Investigation Report (PSR) calculated a base offense level of 26, resulting in an advisory guidelines range of 63 to 78 months imprisonment. However, the district court varied upward and sentenced Dickson to 120 months, finding him to be an essential participant in the conspiracy.The United States District Court for the District of North Dakota initially sentenced Dickson to 120 months imprisonment, but the Eighth Circuit Court of Appeals remanded for resentencing due to procedural errors. The district court had varied upward from the guidelines range without providing adequate notice. On remand, the district court gave notice of its intent to vary upward again and reimposed the 120-month sentence, citing Dickson's significant role in the conspiracy.The United States Court of Appeals for the Eighth Circuit reviewed the case. The court found no procedural error in the district court's resentencing, as it had provided proper notice and based its decision on the trial evidence. The court also found the sentence substantively reasonable, noting that the district court had considered the statutory sentencing factors and the nature of Dickson's involvement in the conspiracy. The Eighth Circuit affirmed the district court's judgment, upholding the 120-month sentence. View "United States v. Dickson" on Justia Law

Ronald Williams, a driver for hire, was convicted of sex trafficking and conspiracy to commit sex trafficking. In April 2018, Williams transported two teenage girls, Hannah Brown and Cyan Smith, for commercial sex work at the behest of his co-defendant, Kennedy Spencer. Both girls were minors and vulnerable, with histories of mental health challenges. Spencer arranged for the girls to engage in commercial sex acts, and Williams facilitated their transportation and received a portion of the earnings.The United States District Court for the Northern District of Illinois, Eastern Division, tried Williams and Spencer jointly. On November 1, 2022, a jury found both men guilty of conspiracy to commit sex trafficking and sex trafficking of both Hannah and Cyan. Williams appealed his conviction, arguing insufficient evidence to support the jury's verdict.The United States Court of Appeals for the Seventh Circuit reviewed the case. The court noted that Williams bore a heavy burden to overturn the jury's verdict, requiring the record to be devoid of evidence supporting guilt beyond a reasonable doubt. The court found sufficient evidence that Williams knew Spencer intended to use the girls for commercial sex acts, facilitated their transportation, and profited from their exploitation. Additionally, the court determined that Williams had a reasonable opportunity to observe that both girls were minors, satisfying the statutory requirements under 18 U.S.C. § 1591 and § 1594.The Seventh Circuit affirmed Williams's conviction, concluding that the jury had sufficient evidence to find him guilty of sex trafficking and conspiracy to commit sex trafficking. View "USA v Williams" on Justia Law