Justia Criminal Law Opinion Summaries

The State of Utah charged Kouri Darden Richins with aggravated murder and other crimes. The case received significant media attention, with extensive coverage from various media outlets. The State and Richins jointly requested that jury selection be held in person and that the jury venire be expanded to include prospective jurors from both Summit and Salt Lake counties. The Third District Court has a standing order requiring virtual jury selection unless "extraordinary circumstances" are found. The Presiding Judge denied the request for in-person jury selection, stating that media attention did not constitute extraordinary circumstances. The Trial Judge initially granted the request to expand the jury venire but later reversed his decision.The Third District Court's Presiding Judge denied the request for in-person jury selection, concluding that the intense media attention did not constitute extraordinary circumstances. The Trial Judge initially approved the request to expand the jury venire but reversed his decision after the Presiding Judge's order, concluding that Utah law did not permit summoning jurors from multiple counties for one trial.The Supreme Court of the State of Utah reviewed the case. The court held that the Presiding Judge did not abuse her discretion in denying the request for in-person jury selection, as the decision was within the bounds of reasonability. The court also held that the Trial Judge correctly interpreted Utah law, which requires jurors to be selected from a single county. The court affirmed the decisions of both the Presiding Judge and the Trial Judge, concluding that the requests for in-person jury selection and an expanded jury venire were properly denied. View "State v. Richins" on Justia Law

Dennis Hale was convicted of raping his step-granddaughter, a minor, starting when she was eight years old. The abuse was reported by the victim to her teachers in September 2021, leading to Hale's arrest and charge in Sevier County. Initially represented by a public defender, Hale later had LaTonya Austin appointed as his attorney due to a conflict. Hale filed multiple pro se motions expressing his desire to represent himself, which the court eventually granted after multiple hearings and warnings about the risks of self-representation. Austin was appointed as standby counsel.The Sevier County Circuit Court found Hale guilty of rape based on the victim's detailed testimony and corroborating evidence, including items found during a search of Hale's property. Hale was sentenced to life imprisonment. He appealed, arguing insufficient evidence, improper waiver of his right to counsel, and error in appointing Austin as standby counsel.The Arkansas Supreme Court reviewed the case. It held that the victim's testimony alone constituted substantial evidence to support the conviction, as corroborated by physical evidence. The court found that Hale knowingly and intelligently waived his right to counsel, having been repeatedly warned of the dangers of self-representation. The court also determined that Hale's conduct at trial did not prevent a fair and orderly exposition of the issues. Finally, the court ruled that there is no constitutional right to choose standby counsel, and Hale had agreed to Austin's appointment.The Arkansas Supreme Court affirmed Hale's conviction and life sentence, finding no reversible errors in the proceedings. View "Hale v. State" on Justia Law

Conrad Calvin Ziegler was charged with criminal mischief and stalking based on his actions toward a couple who were witnesses against him in a separate domestic violence case. The couple reported that Ziegler repeatedly drove around their block, made threatening statements, and later, bags of human feces began appearing in their yard. Security cameras captured vehicles similar to Ziegler's near the couple's property. Additionally, Ziegler was recorded vandalizing one of the victim's vehicles, causing significant damage.The District Court of McHenry County, Northeast Judicial District, presided over the case. During the trial, the court admitted testimony and exhibits related to the valuation of damages to the victim's vehicle over Ziegler's hearsay objections. The jury convicted Ziegler of both charges, and the court entered an amended judgment.The Supreme Court of North Dakota reviewed the case. Ziegler argued that the district court erred in admitting hearsay evidence and that there was insufficient evidence to support his stalking conviction. The Supreme Court held that while the insurer's offer letters were inadmissible hearsay, the error was harmless because the victim's testimony regarding the vehicle's damage was properly admitted under the property owner rule. The court also found sufficient evidence to support the stalking conviction, noting Ziegler's repeated acts of harassment and intimidation directed at the couple.The Supreme Court of North Dakota affirmed the amended criminal judgment, concluding that the district court did not abuse its discretion and that the evidence presented at trial was sufficient to support the jury's verdict. View "State v. Ziegler" on Justia Law

Artur Skobodzinski was driving a commercial vehicle when he was stopped by a North Dakota Highway Patrol trooper for a safety inspection. The trooper detected an odor of alcohol and observed that Skobodzinski had bloodshot eyes. Skobodzinski denied recent alcohol consumption and refused field sobriety tests. He also refused an on-site screening test and a chemical breath test, leading to his arrest for driving under the influence. Skobodzinski requested to speak with an attorney but was only allowed to do so over an hour later at the law enforcement center.The Department of Transportation held an administrative hearing and found that Skobodzinski refused the chemical test and had a reasonable opportunity to contact an attorney. Consequently, his driving privileges were revoked for 180 days. The district court affirmed this decision.The North Dakota Supreme Court reviewed the case and concluded that the hearing officer did not err in finding that Skobodzinski refused the chemical test. However, the court found that the hearing officer erred in determining that Skobodzinski was given a reasonable opportunity to speak with an attorney. The court noted that the trooper could have allowed Skobodzinski to contact an attorney immediately after his request, rather than delaying it until they reached the law enforcement center. The court emphasized that the trooper's delay deprived Skobodzinski of a meaningful opportunity to consult with an attorney and potentially cure his refusal to take the chemical test.The North Dakota Supreme Court reversed the district court’s judgment and the hearing officer’s decision, thereby reinstating Skobodzinski’s driving privileges. View "Skobodzinski v. NDDOT" on Justia Law

Brent Burton was charged with domestic violence, a class B misdemeanor, after a 911 call was made from his residence reporting an assault. The call was purportedly made by Burton's wife, who described being grabbed and slapped by Burton. The State filed a notice of intent to use the 911 call recording as evidence, supported by a certificate of authenticity from the records custodian of Central Dakota Communications. Burton pleaded not guilty and proceeded to trial.At the jury trial, the State was unable to locate or subpoena Burton's wife. Burton objected to the introduction of the 911 call recording, arguing it violated his Sixth Amendment right to confront his accuser. The district court admitted the recording, finding it addressed an ongoing emergency. The jury found Burton guilty, and the court sentenced him accordingly.Burton appealed to the Supreme Court of North Dakota, arguing the admission of the 911 call violated his Sixth Amendment rights and that the recording was improperly authenticated and contained inadmissible hearsay. The Supreme Court reviewed the case de novo and concluded the 911 call was nontestimonial, as its primary purpose was to address an ongoing emergency. The court also found sufficient circumstantial evidence to authenticate the call and determined it fell under the present sense impression exception to the hearsay rule.The Supreme Court of North Dakota affirmed the district court's judgment, holding that the admission of the 911 call did not violate Burton's constitutional rights and that the recording was properly authenticated and admissible under the hearsay exceptions. View "State v. Burton" on Justia Law

Ralph Harris was convicted in three separate cases involving murder, attempted robbery, and aggravated criminal sexual assault. He filed an omnibus motion to suppress his confessions, alleging they were obtained through physical and mental coercion by detectives. The circuit court denied the motion, finding the confessions were voluntary. Harris was convicted, and his convictions were affirmed on direct appeal.Harris then filed postconviction petitions under the Post-Conviction Hearing Act, alleging newly discovered evidence of a pattern of police torture corroborated his claims of coerced confessions. The circuit court advanced the petitions to a third-stage evidentiary hearing but ultimately denied relief, finding the new evidence did not prove his confessions were coerced. Harris appealed, and the appellate court reversed, remanding for a new suppression hearing to consider the new evidence.On remand, a new judge conducted the suppression hearing and denied Harris's coercion claim but vacated his convictions and ordered new trials, citing the potential impact of the new evidence on a jury. The State appealed, arguing the appellate court had jurisdiction to review the circuit court's order. Harris moved to dismiss the appeal, claiming it was an unauthorized interlocutory appeal.The Illinois Supreme Court reviewed the case and held that the appellate court had jurisdiction to consider the State’s appeal. The court found that the appellate court in Harris I had not vacated Harris’s convictions or ordered new trials but had remanded for a new suppression hearing. The proceedings on remand were a continuation of the postconviction proceedings, resulting in a final order from which the State could appeal. The court reversed the appellate court's dismissal and remanded for consideration of the State's appeal. View "People v. Harris" on Justia Law

Jatterius L. Yankaway was arrested on April 7, 2020, for allegedly shooting Robert Hunter on July 26, 2019. Due to the COVID-19 pandemic, the Illinois Supreme Court had tolled speedy-trial terms in criminal proceedings. On September 19, 2022, a jury found Yankaway guilty of attempted first-degree murder, aggravated battery, and unlawful possession of a weapon by a felon (UPWF). The Peoria County circuit court sentenced him to consecutive prison terms for attempted murder and aggravated battery but reserved sentencing on the UPWF conviction.On appeal, Yankaway argued ineffective assistance of counsel for failing to file a speedy-trial demand under the intrastate detainers statute, that his convictions violated the one-act, one-crime rule, and that the circuit court misapprehended the minimum sentence for attempted first-degree murder. The appellate court affirmed in part, finding no ineffective assistance as Yankaway could not show prejudice, and no plain error in sentencing. However, it vacated the aggravated battery conviction under the one-act, one-crime rule and remanded for sentencing on the UPWF conviction.The Illinois Supreme Court reviewed the case. It affirmed the appellate court's judgment regarding counsel's effectiveness but on different grounds, and it affirmed the sentencing for Yankaway’s convictions. The court found that the intrastate detainers statute did not apply to Yankaway as he was not committed to the Department of Corrections when the State proceeded on one of his charges. The court also found that defense counsel performed deficiently by failing to object to a continuance but held that this did not prejudice Yankaway as the continuance was attributable to him. The court concluded that the circuit court did not abuse its discretion in attributing the continuance to Yankaway and denying his motion to dismiss. Finally, the court found no plain error in the sentencing decision. The part of the appellate court judgment remanding for sentencing on the UPWF conviction was vacated. View "People v. Yankaway" on Justia Law

Travaris T. Guy was convicted of attempted first degree murder and second degree murder for the shooting of David Woods Sr. and Sheena Woods. The jury found that Guy acted with the intent to kill but also believed his actions were lawfully justified, which led to an inconsistent verdict. Guy did not raise this issue on direct appeal or in his initial postconviction petition but later filed a successive postconviction petition claiming inconsistent verdicts and ineffective assistance of counsel.The Will County circuit court denied relief on the inconsistent verdict claim but granted a new trial on a separate claim. The appellate court reversed Guy’s attempted first degree murder conviction, holding that the jury instruction misstated the law, the conviction was inconsistent with the second degree murder conviction, and the jury’s finding of self-defense precluded a guilty verdict for attempted first degree murder.The Illinois Supreme Court reviewed the case and affirmed the appellate court’s judgment in part, reversed in part, and remanded to the circuit court to sentence Guy on the lesser-included offense of aggravated battery with a firearm. The court held that a conviction for attempted first degree murder requires proof of intent to kill without lawful justification. The jury instruction was erroneous as it only required intent to kill. The jury’s finding that Guy believed in the need for self-defense was incompatible with the intent required for attempted first degree murder. The court also found that Guy’s attorneys were ineffective for failing to properly raise these issues. View "People v. Guy" on Justia Law

Elvis Wynn was convicted by a Knox County jury of first-degree bail jumping and being a first-degree persistent felony offender (PFO) after failing to appear at an October 2022 sentencing hearing for previous charges. The Knox Circuit Court sentenced him to twenty years of imprisonment based on the jury's recommendation. Wynn appealed the convictions.Previously, in September 2022, Wynn had pled guilty to possession of a firearm by a convicted felon, operating a motor vehicle under the influence, and second-degree PFO. He was released on home incarceration and ordered to appear for sentencing in October 2022, which he failed to do. Consequently, he was indicted on new charges of first-degree bail jumping and first-degree PFO. After being arrested in February 2023, he received a seven-year sentence for the original charges. In September 2023, a jury trial was held for the new charges, resulting in his conviction and the twenty-year sentence.The Supreme Court of Kentucky reviewed Wynn's appeal, where he argued that the trial court erred by admitting evidence of his prior felony charges and that his twenty-year sentence violated the statutory sentencing cap. The court found that while the trial court abused its discretion by admitting the video of Wynn's prior court appearance, this error was harmless given the nature of the charges and the compelling evidence against him.Regarding the sentencing issue, the court distinguished Wynn's case from Kimmel v. Commonwealth, noting that Wynn's sentences arose from separate indictments and trials. Therefore, the statutory sentencing cap did not apply, and the trial court correctly ordered the sentences to run consecutively, resulting in an aggregate sentence exceeding twenty years. The Supreme Court of Kentucky affirmed the judgment of the Knox Circuit Court. View "WYNN V. COMMONWEALTH OF KENTUCKY" on Justia Law

Darryl Ellery pled guilty to first-degree assault and was sentenced to five years in prison, probated for five years, with a restitution order of $305.14 to be paid monthly. In January 2017, a probation officer recommended revoking Ellery’s probation for absconding, and a warrant was issued. The warrant was served in October 2021, and at a November 15, 2021, hearing, the court granted a continuance but did not extend Ellery’s probation. At a subsequent hearing, Ellery argued the court lost jurisdiction as his probation expired in June 2021 without extension. The court rejected this and revoked his probation.Ellery appealed, and the Kentucky Court of Appeals held that the trial court lost jurisdiction when it failed to extend Ellery’s probation at the November 15, 2021, hearing. The court also rejected the Commonwealth’s argument to adopt the fugitive tolling doctrine, citing separation of powers and lack of legislative enactment.The Supreme Court of Kentucky reviewed the case. The Commonwealth argued for reinstating the revocation, suggesting the court should adopt the fugitive tolling doctrine or reinterpret KRS 533.020(4). Ellery countered that the appeal was moot as he completed his sentence and argued against adopting the fugitive tolling doctrine.The Supreme Court of Kentucky held that the appeal was not moot under the public interest exception. The court reaffirmed its interpretation of KRS 533.020(4) from Commonwealth v. Tapp, which requires a duly entered court order to extend probation. The court declined to adopt the fugitive tolling doctrine, citing legislative intent and separation of powers. The court concluded that the circuit court lost jurisdiction when it failed to extend Ellery’s probation at the November 15, 2021, hearing, affirming the Court of Appeals' decision. View "COMMONWEALTH OF KENTUCKY V. ELLERY" on Justia Law