Justia Criminal Law Opinion Summaries

Two individuals, Taurean Tyler and DeAngelo Mixon, were shot from behind while walking to a friend’s house in Chicago; Tyler died, and Mixon survived. The identity of the shooter was the sole contested issue at trial. Four eyewitnesses testified: Mixon and Tristan Thomas, both friends of the victims who knew the defendant, Antrell Johnson, for years, initially identified Johnson as the shooter in out-of-court statements but tried to recant at trial. Janeese Washington, an uninvolved bystander, consistently identified Johnson, both in a photo array and at trial, while her husband, Robert Laster, did not make an identification. There was no physical evidence or motive linking Johnson to the crime.A jury in the Circuit Court of Cook County found Johnson guilty of first degree murder but acquitted him of attempted murder. Johnson’s posttrial motion challenging the sufficiency of the evidence was denied. On appeal, a divided panel of the Appellate Court of Illinois, First District, reversed the conviction, finding the State failed to prove guilt beyond a reasonable doubt. The majority applied the reliability factors from Neil v. Biggers, typically used for assessing suggestive identification procedure admissibility, instead of the sufficiency of the evidence standard from Jackson v. Virginia. The appellate majority also relied on social science research not presented at trial and cited the split verdict as undermining the reliability of the identifications.The Supreme Court of the State of Illinois reversed the appellate court’s judgment. It held that the appellate court erred by substituting the Biggers admissibility test for the Jackson sufficiency standard, by improperly considering extra-record social science literature, and by relying on the split verdict to undermine the jury’s credibility determinations. The Illinois Supreme Court found the identification evidence sufficient for conviction and remanded the case for appellate consideration of the ineffective assistance of counsel claim. View "People v. Johnson" on Justia Law

In 1986, a liquor store robbery in Chicago resulted in the shooting death of the store’s owner, Nazih Youssef. Multiple eyewitnesses identified Michael McCoy and another man, Wayne Millighan, as present during events leading up to the crime; two witnesses specifically identified McCoy as the shooter both at the scene and in court. Physical evidence included a presumptive blood test on McCoy’s shoes, though this could not conclusively identify the substance as human blood. McCoy was arrested shortly after the crime, matching the descriptions given by witnesses.After a jury trial in the Circuit Court of Cook County, McCoy was convicted of first degree murder and armed robbery and sentenced to life imprisonment. His convictions were affirmed on direct appeal by the Illinois Appellate Court. Over the years, McCoy filed several postconviction petitions, all of which were denied. Eventually, he was granted leave to file a successive postconviction petition, raising claims of actual innocence based on new affidavits from Millighan naming another man as the shooter, expert testimony questioning the reliability of eyewitness identifications, and expert analysis challenging the blood evidence.The Circuit Court held a third-stage evidentiary hearing but denied relief, finding that Millighan’s new testimony was not credible and that the expert evidence was not conclusive enough to probably change the result at retrial. The Illinois Appellate Court affirmed, concluding that the outcome hinged on Millighan’s credibility, which the Circuit Court was best positioned to assess.The Supreme Court of the State of Illinois reviewed the case and affirmed the lower courts’ decisions. The court held that McCoy failed to establish by a preponderance of the evidence that the new evidence was of such a conclusive character that it would probably change the result upon retrial; thus, denial of his successive postconviction petition was not manifestly erroneous. View "People v. McCoy" on Justia Law

The defendant was incarcerated in Will County, Illinois, awaiting trial on charges of sexual abuse. While in jail, he approached two different inmates on separate occasions, offering them money to murder individuals connected to the sexual abuse case, including the alleged victims and two detectives. The second inmate, Daniel Robinson, reported the solicitation to authorities and cooperated with law enforcement by recording conversations with the defendant in which they discussed plans and payments. The defendant transferred money and property to Robinson as part of these arrangements. Robinson never intended to commit the murders and was acting in coordination with investigators.A Will County jury convicted the defendant of two counts of solicitation of murder for hire and five counts of solicitation of first degree murder. The five solicitation of murder convictions were merged with the two solicitation of murder for hire convictions. The Circuit Court of Will County sentenced him to consecutive prison terms of 39 and 37 years. The defendant appealed, arguing that his convictions for solicitation of murder for hire could not stand because the person he solicited did not actually intend to carry out the murders, and therefore the statutory requirement that he “procure another” was not met. The Illinois Appellate Court, Third District, affirmed the convictions, finding that a conviction could be supported even if the person solicited only feigned agreement.The Supreme Court of the State of Illinois granted leave to appeal to determine whether the offense of solicitation of murder for hire requires proof that the person solicited genuinely intended to commit murder. The court held that, under Illinois law, solicitation of murder for hire encompasses unilateral agreements; the defendant’s intent and actions to procure another, regardless of the other party’s true intent, are sufficient for conviction. The court affirmed the judgments of the lower courts. View "People v. Shepherd" on Justia Law

The case concerns Michael Gibbs, who was convicted in Hopkins County, Kentucky, of multiple sexual offenses involving three minor victims. The victims, all girls under the age of twelve at the time of the offenses, were friends, and two were frequent visitors at Gibbs’ home. One victim reported to police that Gibbs gave her marijuana and engaged in sexual intercourse with her. The police investigation, which included interviews and extraction of messages and images from cell phones, uncovered sexual abuse of two additional minors. The crimes included rape, incest, sexual abuse, possession and distribution of child sexual images, and promoting sexual performances by a minor.In the Hopkins Circuit Court, Gibbs moved to sever the charges relating to each victim, arguing that the cases were too dissimilar to be tried together. The court denied the motion, finding that the crimes showed a common scheme or plan, as all the victims were young, friends of each other, and the offenses occurred in the same location and time frame. The court also allowed one victim, Alice, to testify via closed circuit television due to her post-traumatic stress disorder and developmental delays, based on testimony from her therapist. The jury convicted Gibbs on all charges except for one and recommended a life sentence, which the trial court imposed.The Supreme Court of Kentucky reviewed Gibbs’ appeal as a matter of right. The Court held that the trial court did not abuse its discretion in denying the motion to sever, finding sufficient similarities and a logical relationship among the offenses to justify joinder. The Court also upheld the decision to allow Alice to testify via closed circuit television, reaffirming that child victims who were under twelve when the crimes occurred may testify this way even if they are older at trial, provided they are still children. The judgment of the Hopkins Circuit Court was affirmed. View "GIBBS V. COMMONWEALTH OF KENTUCKY" on Justia Law

Marvin Johnson was convicted of multiple offenses, including the kidnapping and murder of his ex-girlfriend’s son, as well as rape and aggravated robbery of his ex-girlfriend. The crimes occurred after Johnson’s relationship with his ex-girlfriend ended and he was told to move out of her house. Johnson harbored resentment and, after discussing violent intentions with a friend, returned to his ex-girlfriend’s home, killed her son, and then assaulted and robbed her. He was apprehended while attempting to flee and much of the stolen money, as well as other incriminating evidence, was recovered.An Ohio jury convicted Johnson of all charges and recommended the death penalty, which the trial court imposed. The Ohio Supreme Court affirmed his convictions and sentence. Johnson unsuccessfully pursued postconviction relief and applications to reopen his appeal, claiming ineffective assistance of counsel at trial and on appeal. He then filed a federal habeas corpus petition in the United States District Court for the Southern District of Ohio, which was denied. While his federal appeal was pending, a state court vacated his death sentence after finding him seriously mentally ill and resentenced him to life without parole, but left his convictions intact.The United States Court of Appeals for the Sixth Circuit reviewed whether the resentencing rendered the federal habeas petition moot. The court held that Johnson’s claims regarding the guilt phase of his trial were not moot and that it still had jurisdiction because Johnson remains incarcerated based on the underlying convictions. The court then addressed Johnson’s claims of ineffective assistance of counsel. After reviewing the record and arguments, the Sixth Circuit concluded that Johnson failed to show prejudice resulting from his trial or appellate counsel’s performance. Accordingly, the court affirmed the denial of habeas relief. View "Johnson v. Bobby" on Justia Law

An agent employed by Immigration and Customs Enforcement supervised participants in an Alternatives-to-Detention program, which allowed him significant discretion over their conditions, such as monitoring protocols and the handling of their passports. The agent engaged in sexual relations with multiple women under his supervision, violating agency policy. After one participant reported his behavior, an investigation revealed further evidence of misconduct, including deleted photos and communications. The agent attempted to impede the investigation by providing lenient supervision to a participant in exchange for her silence. One supervisee accused the agent of sexual assault, testifying to repeated coerced encounters.A jury in the United States District Court for the Southern District of Ohio convicted the agent on several counts, including depriving a person of constitutional rights under color of law, obstructing a sex-trafficking investigation, witness tampering, and destruction of records. The district court sentenced him to 144 months in prison. During trial, the court excused an ill juror during deliberations, which the defendant challenged as an abuse of discretion. He also argued that multiple counts were improperly multiplicitous, raising double jeopardy concerns, and challenged several sentencing enhancements.The United States Court of Appeals for the Sixth Circuit reviewed the case. It held that the district court did not abuse its discretion in excusing the juror due to medical necessity. The appellate court found no plain error regarding multiplicity, as each contested count required proof of distinct elements or conduct. The court also upheld the sentencing enhancements, finding no error in applying an obstruction of justice enhancement to pre-investigation conduct under the amended Sentencing Guidelines, no impermissible double counting, and no error regarding the sentencing guidelines in relation to statutory maximums. The requirement that the defendant register as a sex offender was also affirmed. The Sixth Circuit affirmed the convictions and sentence in all respects. View "United States v. Golobic" on Justia Law

After a multi-car collision in August 2021, law enforcement found a man unconscious behind the wheel of his vehicle. An officer administered Narcan to revive him, and paramedics transported him to the hospital. During his treatment, the man told paramedics and later his girlfriend that he had used heroin. His girlfriend relayed this information to a nurse. Following the incident, a district court judge issued a warrant allowing law enforcement to obtain the man’s medical records and ambulance run sheets for the day of the accident. The records included statements made to both the paramedics and his girlfriend.After he was charged with driving under the influence of a controlled substance, he moved to suppress the medical records and ambulance reports, arguing that disclosure violated statutory medical privilege and that the warrant was overbroad. The District Court for Hennepin County suppressed some records but ruled that neither the physician-patient privilege nor the nurse-patient privilege protected his statements to the paramedics or his girlfriend, nor his girlfriend’s statements. The court also found the warrant sufficiently particular. After a jury convicted him, he appealed.The Minnesota Court of Appeals affirmed, holding that paramedics are excluded from the physician-patient privilege, the privilege did not cover statements made to his girlfriend, and the search warrant was not overbroad.The Minnesota Supreme Court reviewed the case and clarified that the physician-patient privilege can extend to paramedics only if they act under the direction of a treating physician, but found the accused did not show such a relationship existed here. The court held that statements to a girlfriend who is not a necessary or customary participant in treatment are not privileged, and that nonprivileged information does not become privileged simply by inclusion in medical records. The court also held that the privilege does not bar issuing a particularized warrant for medical records in these circumstances. The decision of the court of appeals was affirmed. View "State of Minnesota vs. Smeby" on Justia Law

After being arrested for the death of his girlfriend, the defendant was initially charged with second-degree intentional murder and second-degree felony murder. He was represented by a public defender for about six months. The defendant then requested to represent himself, citing conflicts with his attorney and the inability to obtain substitute counsel from the public defender’s office. At a hearing, the district court discussed the risks of self-representation with the defendant, reviewed a written petition to proceed pro se, and found the defendant lucid and thoughtful. The court allowed the defendant to waive his right to counsel and appointed advisory counsel.About a week later, a grand jury indicted the defendant on a new, more serious charge: first-degree domestic abuse murder, carrying a potential life sentence. At a subsequent hearing, the district court explained the increased stakes and confirmed that the defendant understood the new penalties and still wished to represent himself. The defendant continued pro se through pretrial motions, a stipulated-facts court trial, and sentencing, ultimately being convicted and sentenced to life in prison with the possibility of supervised release after 30 years.On direct appeal to the Minnesota Supreme Court, the defendant argued that his initial waiver of counsel was not knowing, voluntary, and intelligent, and that after the indictment, the district court failed to obtain a valid renewed waiver in light of the increased charges and penalties. The Minnesota Supreme Court reviewed the district court’s factual findings for clear error and its legal conclusions de novo. It held that the district court did not err in finding both the initial waiver and the renewed waiver valid, given the defendant’s consultation with counsel, the comprehensive advisement by the court, and the defendant’s clear understanding of the risks. The conviction was affirmed. View "State of Minnesota vs. Turner" on Justia Law

Arturo Mendoza created and uploaded fourteen images of morphed child pornography using Adobe Photoshop and cloud storage services. The images depicted adult sexual activity with the faces of two minor girls, ages twelve and six, photoshopped onto adult women’s bodies. Mendoza was indicted and pleaded guilty to one count of transporting child pornography under 18 U.S.C. § 2252A(a)(1), (b)(1). At sentencing, the presentence report recommended certain financial conditions related to restitution and a location-monitoring condition for supervised release.The United States District Court for the Southern District of Texas adopted the presentence report and sentenced Mendoza to 120 months’ imprisonment, an above-Guidelines sentence, followed by ten years of supervised release. The district court left restitution open for ninety days but never entered an order for restitution, as no hearing was requested or held. The written judgment included special conditions: a location-monitoring requirement (with unclear duration and a home-detention component), and financial-disclosure and credit-approval conditions. Mendoza appealed, challenging these supervised release conditions.The United States Court of Appeals for the Fifth Circuit reviewed the case. The court found that the district court erred by imposing a home-detention component in the written judgment when only standalone location monitoring was pronounced orally, and by failing to specify the duration of the location-monitoring condition, violating due process. Additionally, the appellate court held that the financial-disclosure and credit-approval conditions were imposed in error because restitution was never ordered and the record did not support these restrictions. The Fifth Circuit vacated all three challenged conditions and remanded for proceedings consistent with its opinion, specifically for correction of the location-monitoring condition and for further proceedings regarding the financial conditions. View "United States v. Mendoza" on Justia Law

In 1974, a fatal shooting occurred in a Boston park, resulting in the death of a fourteen-year-old victim. The suspect, who was twenty years old at the time, was identified by witnesses and a murder complaint was issued against him. Shortly after the incident, the suspect was arrested in Indiana under an alias for an unrelated crime. After being acquitted of that charge, he was mistakenly released, and his whereabouts were unknown to Massachusetts authorities for nearly two decades. During this period, he lived under his own name in Indiana, worked, attended university, and occasionally used aliases when interacting with law enforcement.Following a renewed discovery of his location in 1994, Massachusetts authorities interviewed and indicted him for murder in 1997. He was tried and convicted in 2004. Prior to trial, the defendant filed multiple motions to dismiss the indictment on speedy-trial grounds, all unsuccessful. The Massachusetts Superior Court and then the Supreme Judicial Court (SJC) rejected his arguments, finding that the delay was largely attributable to his own conduct, including the use of aliases. The SJC also denied his ineffective-assistance-of-counsel claims on direct appeal.The United States District Court for the District of Massachusetts denied his habeas petition, which alleged violations of his Sixth Amendment right to a speedy trial and ineffective assistance by counsel. On appeal, the United States Court of Appeals for the First Circuit held that, under binding federal precedent, the speedy-trial right only attached upon indictment, not at the issuance of the complaint, and since the relevant delay was seven years, not thirty, his federal speedy-trial claim failed. The court also found his ineffective-assistance claims unavailing, as the record showed no deficient performance or prejudice. Therefore, the First Circuit affirmed the denial of habeas relief. View "Carr v. Lizotte" on Justia Law