Justia Criminal Law Opinion Summaries

Ryan Charles Rooney was found guilty of first-degree domestic abuse murder after a jury trial and was sentenced to life in prison with the possibility of parole. Rooney appealed, arguing that the district court abused its discretion by precluding his alternative-perpetrator evidence and erred in denying his motion to suppress statements made to police officers. The case involves the murder of Rooney’s wife, Samantha Columbus-Boshey, whose body was found in a hotel room they had been staying in with her two young children.The district court precluded Rooney's alternative-perpetrator evidence, finding that he did not meet the foundational requirement to introduce such evidence. Additionally, the court denied Rooney's motion to suppress his statements to police officers, concluding that the statements were made voluntarily despite Rooney's head injury and hospitalization.The Minnesota Supreme Court reviewed the case and affirmed the district court's decisions. The court held that the district court did not abuse its discretion in precluding the alternative-perpetrator evidence, as Rooney failed to provide evidence with an inherent tendency to connect the third person, D.G., to the actual commission of the crime. The court also found that the district court correctly determined that Rooney's statements to police were voluntary, considering the totality of the circumstances, including his ability to comprehend and the nature of the interrogation.The Supreme Court concluded that the district court's rulings were based on a correct application of the law and were supported by the evidence. Therefore, the judgment of conviction was affirmed. View "State of Minnesota vs. Rooney" on Justia Law

Detective Genaro Hernandez, a Dallas Police Department detective, was involved in a shooting investigation outside The Green Elephant bar in August 2019. Hernandez, who also worked for the Stainback Organization, allegedly pursued false charges against the bar's owner, Shannon McKinnon, and a security guard, Guadalupe Frias, to benefit his private employer. Despite the Special Investigation Unit finding no criminal offense by the plaintiffs, Hernandez bypassed standard procedures and directly sought prosecution from the Dallas County District Attorney’s Office, leading to the plaintiffs' indictment for tampering with evidence. The charges were later dropped when Hernandez's conflict of interest was revealed during Frias's trial.The plaintiffs filed a lawsuit against Hernandez, alleging federal claims under 42 U.S.C. § 1983 for false arrest and malicious prosecution, and state-law claims for malicious prosecution, false imprisonment, and civil conspiracy. The United States District Court for the Northern District of Texas dismissed the federal malicious-prosecution claim but allowed the federal false-arrest claim and the state-law claims to proceed. Hernandez appealed, arguing he was entitled to governmental immunity under the Texas Tort Claims Act.The United States Court of Appeals for the Fifth Circuit reviewed the case and determined that Hernandez's actions, despite being motivated by personal interests, fell within the scope of his employment as a detective. The court held that Texas law provides broad immunity to state actors for actions within their employment scope, regardless of intent. Consequently, the court reversed the district court's decision denying dismissal of the state-law claims and remanded the case for further proceedings on the remaining federal claim. View "Frias v. Hernandez" on Justia Law

In January 2018, Nycole Amaury Rosario Sánchez, then fifteen years old, and six accomplices committed a series of violent crimes in Puerto Rico, including three robberies, two carjackings, and four murders. Rosario brandished and discharged firearms during these crimes, resulting in multiple injuries and deaths. He was arrested on January 25, 2018, and agreed to be prosecuted as an adult. Rosario pleaded guilty to six counts, including interference with commerce by robbery, carjacking, and using a firearm during a crime of violence causing murder.The United States District Court for the District of Puerto Rico sentenced Rosario to 480 months' imprisonment. Rosario appealed, arguing that the district court failed to consider mitigating factors such as his age, mental and emotional condition, and the sentencing disparity between him and his co-defendants. He also claimed that his sentence was both procedurally and substantively unreasonable.The United States Court of Appeals for the First Circuit reviewed the case. The court found that the district court had considered Rosario's age, mental and emotional condition, and other mitigating factors, as evidenced by the sentencing transcript and the Presentence Investigation Report (PSR). The court also noted that Rosario's co-defendants were sentenced by a different judge and that Rosario had not provided sufficient information to establish an unwarranted sentencing disparity.The First Circuit held that the district court did not commit procedural error in its consideration of the section 3553(a) factors or in addressing the sentencing disparity. The court also found that Rosario's sentence was substantively reasonable, given the seriousness of his offenses and his behavior while incarcerated. Consequently, the First Circuit affirmed Rosario's 480-month sentence. View "United States v. Rosario Sanchez" on Justia Law

Michael David Geist was convicted of simple assault on a law enforcement officer and criminal trespass following a jury trial. The incident occurred on April 14, 2023, when Officer Dalton Santana responded to a report of a disruptive male patron at the Mount Rushmore Casino. Geist, identified as the disruptive individual, was irascible and under the influence of a substance. When Officer Santana attempted to transport Geist to a detoxification center, Geist resisted, resulting in a physical altercation where Geist allegedly kicked Officer Santana.The Circuit Court of the Seventh Judicial Circuit, Pennington County, South Dakota, admitted a recording from Officer Zachary Simons’s body camera under the silent witness theory, despite Geist’s objection. Geist argued that the recording should not be admitted without Officer Simons’s testimony, as he was unavailable due to military deployment. The court overruled the objection, admitting the footage based on the testimony of James Chastain, a video evidence technician, who authenticated the recording.The Supreme Court of the State of South Dakota reviewed the case. The court held that the circuit court did not abuse its discretion in admitting the body camera footage under the silent witness theory. The court found that sufficient foundational facts were presented to authenticate the video, including the technical details of the body camera system and the consistency of the footage with other unchallenged evidence. The court also determined that even if the admission was erroneous, it did not prejudice Geist, as the other evidence presented was strong and consistent with the State’s case. Consequently, the Supreme Court affirmed the circuit court’s decision. View "State v. Geist" on Justia Law

The case involves allegations of child molestation against the defendant, who was indicted on one count of first-degree child molestation and two counts of second-degree child molestation. The complaining witness, a minor, accused the defendant of multiple instances of molestation occurring when she was between four and eight years old. The defendant was convicted by a jury on one count of first-degree child molestation and one count of second-degree child molestation. He was sentenced to a sixty-year sentence, with twenty-five years to be served, for the first-degree count, and a concurrent twenty-five-year sentence for the second-degree count.In the Providence County Superior Court, the trial justice granted the defendant’s motion for judgment of acquittal on one of the two counts of second-degree child molestation. The jury found the defendant guilty on the remaining counts. The defendant did not file a motion for a new trial. The trial justice later sentenced the defendant, and a judgment of conviction and commitment was entered.The defendant appealed to the Supreme Court of Rhode Island, arguing that the trial justice erred by allowing a medical expert to testify in a manner that impermissibly bolstered the complaining witness’s testimony. The Supreme Court of Rhode Island reviewed the case and determined that the defendant had not properly preserved his objection to the expert’s testimony for appellate review. The court noted that the defendant failed to object to the specific questions that formed the basis of his appeal and did not move to strike the expert’s answers or request a cautionary instruction. Consequently, the court deemed the issue waived and affirmed the judgment of the Superior Court. View "State v. Lantigua" on Justia Law

Scottie D. Allen, a prisoner under a death sentence, appealed the circuit court's summary denial of his initial motion for postconviction relief under Florida Rule of Criminal Procedure 3.851 and the denial of his request for public records under Rule 3.852. Allen also petitioned for a writ of habeas corpus. Allen was convicted of first-degree premeditated murder for strangling his cellmate, Ryan Mason, at Wakulla Correctional Institution. Allen represented himself during the trial and penalty phases, where he confessed to the murder and declined to present any mitigation.The trial court found Allen competent to waive counsel and represent himself. The jury convicted Allen and recommended the death penalty, finding four aggravating factors. The trial court ordered a presentence investigation report (PSI) and appointed amicus counsel to present mitigation at the Spencer hearing. Despite Allen's objections, the trial court allowed the State's mental health expert to evaluate him. The trial court sentenced Allen to death, finding significant aggravating factors and some mitigating circumstances.On direct appeal, the Florida Supreme Court affirmed Allen's conviction and death sentence. Allen then filed a motion for postconviction relief, raising several claims, including issues with the PSI, the trial court's handling of mitigation, and his competency to represent himself. The circuit court summarily denied the motion, finding the claims procedurally barred or without merit.The Florida Supreme Court reviewed the case and affirmed the circuit court's denial of postconviction relief and the request for additional public records. The court found that Allen's claims were procedurally barred as they could have been raised on direct appeal and were without merit. The court also denied Allen's habeas petition, concluding that his appellate counsel was not ineffective for failing to raise meritless or unpreserved issues. View "Allen v. State of Florida" on Justia Law

Timothy Duke was identified as one of the burglars involved in the theft of numerous items from three properties owned by Joseph Walsh in Cheyenne. The stolen items included cash, collectible coins, firearms, trade tokens, and antique police badges. Following an investigation, police recovered some of the stolen items from Duke's home, vehicle, and trailer. Duke was charged with theft over $1,000 and aggravated burglary with a deadly weapon. He pled guilty to the aggravated burglary charge as part of a plea agreement, and the theft charge was dismissed. Duke agreed to pay restitution jointly and severally with his co-defendants.The District Court of Laramie County held a restitution hearing where Walsh testified about the stolen items and their estimated values. The court also considered a presentence investigation report and victim impact statements. The court ordered Duke to pay $507,000 in restitution, finding the State had provided sufficient evidence to support the amount claimed.The Supreme Court of Wyoming reviewed the case to determine if the district court abused its discretion in setting the restitution amount. The court found that Walsh's testimony, the State's supporting exhibits, and the presentence investigation report provided a reasonable basis for the restitution award. Walsh's detailed testimony about the stolen items and their values, corroborated by the presentence investigation report and victim impact statements, was deemed credible and sufficient.The Supreme Court of Wyoming affirmed the district court's restitution order, concluding that the district court did not abuse its discretion and that the restitution amount was supported by sufficient evidence. View "Duke v. State" on Justia Law

Jeremy Clay was arrested for traffic violations and drug offenses on September 23, 2023, and later charged with failure to register as a convicted sex offender. He pled guilty to the failure to register charge and was sentenced to three to five years of incarceration, with all but thirty days suspended, followed by three years of supervised probation. Clay did not appeal the original judgment and sentence. On June 28, 2024, the State filed a petition to revoke his probation, alleging violations including failure to contact his probation agent, leaving Wyoming without permission, and failing to make a required payment. Clay admitted to the violations at a hearing, and the court revoked his probation, sentencing him to nine months in jail, suspended in favor of a split sentence of seventy-two days in jail followed by three years of supervised probation. He timely appealed the probation revocation order.The Wyoming Supreme Court reviewed the case. Clay's appeal focused on alleged violations of his rights during the original criminal proceedings, including claims of Fourth Amendment violations, prosecutorial misconduct, and ineffective assistance of counsel. The State argued that the court lacked jurisdiction to review these claims because Clay did not appeal the original judgment and sentence within the required thirty days.The Wyoming Supreme Court affirmed the district court's order, applying res judicata principles. The court held that Clay's claims were barred by res judicata because he could have raised them in a direct appeal of the original judgment and sentence but failed to do so. The court determined that the parties, subject matter, and issues were the same in both the original criminal proceeding and the probation revocation, and Clay did not show good cause for failing to raise the issues earlier. As a result, Clay was not entitled to relief from the court. View "Clay v. State" on Justia Law

The case concerns a defendant who pleaded guilty to the premeditated murders of his mother and stepfather. In December 2021, he forced entry into their home, using a stolen firearm to shoot his mother six times and his stepfather four times. The defendant did not contest his responsibility for the crimes. Prior to sentencing, he presented evidence of severe mental illness, a troubled upbringing, and his acceptance of responsibility, seeking more lenient sentences based on these mitigating factors.The Bourbon District Court considered the defendant’s request for concurrent “hard 25” sentences, supported by expert testimony regarding his mental health and background. However, the court found that, while there were mitigating circumstances, they did not rise to the level of “substantial and compelling reasons” required to depart from the statutory “hard 50” sentence for premeditated first-degree murder. The court imposed two consecutive hard 50 sentences, emphasizing the brutal and premeditated nature of the crimes and the impact on the victims’ family. The defendant appealed directly to the Supreme Court of the State of Kansas, arguing that the district court abused its discretion in both the length and the consecutive nature of the sentences.The Supreme Court of the State of Kansas reviewed both sentencing decisions for abuse of discretion. The court held that the district court acted within its lawful discretion in declining to depart from the hard 50 sentences and in ordering the sentences to run consecutively. The court found that the mitigating evidence did not compel a lesser sentence given the facts of the case, and that the decision to impose consecutive sentences was reasonable in light of the gravity of the offenses. The defendant’s sentences were affirmed. View "State v. Mitchell " on Justia Law

Dennis O. Haynes III, serving a life sentence for first-degree murder, filed a motion requesting access to the warrants and their supporting materials in his criminal case. The district court granted him partial relief, allowing access to his arrest warrant and supporting affidavit but denying access to any search-warrant materials.Haynes initially pleaded guilty to multiple charges, including first-degree murder, in 2014 and was sentenced to life imprisonment without parole for 20 years. Nine years later, he filed a habeas corpus motion alleging ineffective assistance of counsel, which was refiled as a separate civil case. Subsequently, Haynes filed a postconviction motion in his criminal case requesting the probable-cause affidavits and all warrants. The district court denied this motion, but upon reconsideration, granted access to the arrest-warrant affidavit while denying access to search-warrant materials.The Kansas Supreme Court reviewed the case and found that K.S.A. 22-2302(b) and K.S.A. 22-2502(d) grant defendants a personal right to access affidavits or sworn testimony supporting arrest and search warrants, respectively, but do not address access to the warrants themselves. The court affirmed the district court's order granting Haynes access to the arrest-warrant affidavit but reversed the order denying access to search-warrant affidavits. The case was remanded with instructions to produce any search-warrant affidavits upon receipt of the necessary fee for production. View "State v. Haynes " on Justia Law