Justia Criminal Law Opinion Summaries

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The Supreme Court affirmed the judgment of the district court convicting Defendant, after a jury trial, of sexual assault in the first degree, holding that the district court did not abuse its discretion in prohibiting Defendant from questioning the complaining witness, J.K., about her prior allegation against a doctor.On appeal, Defendant argued that the district court erred by prohibiting from asking J.K. about an allegation she made against her prenatal doctor regarding inappropriate touching during the course of a prenatal examination. The Supreme Court affirmed, holding that the district court's decision to exclude the evidence did not violate Defendant's constitutional right to confront his accuser. View "State v. Ali" on Justia Law

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The Supreme Judicial Court affirmed the judgment of a single justice of the court denying Petitioner's petition pursuant to Mass. Gen. Laws ch. 211, 3, holding that the single justice did not err or abuse his discretion in denying relief.Petitioner was charged with assault and battery on a family or household member, malicious destruction of property, and intimidation of a witness. After Petitioner unsuccessfully filed several motions to dismiss he filed his Mass. Gen. Laws ch. 211, 3 arguing that the complaint had not been signed by the correct police officer and proceeding to trial on the basis of a nonconforming criminal complaint would violate his due process rights. The previously unsigned complaint was subsequently signed and sworn in open court. Thereafter, the single justice denied Petitioner's Mass. Gen. Laws ch. 211, 3 petition. The Supreme Judicial Court affirmed, holding that there was no reason Petitioner could not obtain his desired relief in a direct appeal. View "Schajnovitz v. Commonwealth" on Justia Law

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The Supreme Judicial Court affirmed the judgment of the county court denying, without a hearing, Petitioner's petition for relief in the nature of certiorari under Mass. Gen. Laws ch. 249, 4, holding that Petitioner failed to establish that he was entitled to extraordinary relief.In his petition, Petitioner sought to have the Supreme Judicial Court intervene in custody and child support proceedings in the probate and family court. The county court denied relief. The Supreme Judicial Court affirmed, holding that the proceedings at issue were reviewable in the ordinary appellate process and that Petitioner, who had twice before sought extraordinary relief in litigation between him and the mothers of his children, was on notice that further attempts to obtain such relief may result in the imposition of sanctions. View "Kifor v. Commonwealth" on Justia Law

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The Supreme Court reversed Defendant's conviction for conspiracy to commit murder, holding that there was insufficient evidence to support the conviction.After a jury trial, Defendant and his codefendants were found guilty of conspiracy to commit murder and other offenses. As to all three defendants, the jury found that the conspiracy was for the benefit of a criminal street gang. Defendant appealed, challenging the sufficiency of the evidence. The court of appeal affirmed. The Supreme Court reversed, holding that, after considering the record in its entirety, the evidence presented at trial was insufficient to show that Defendant had the requisite intent to enter into an agreement to commit murder. View "People v. Ware" on Justia Law

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A jury convicted Defendant on two counts of lying to the FBI, violating 18 U.S.C. § 1001(a)(2). The district court sentenced him to concurrent 60-month prison terms. On appeal, Defendant challenged (1) the district court’s denial of his motion to dismiss Count Two of his indictment as multiplicitous, (2) the sufficiency of the evidence supporting the jury’s verdict, (3) the district court’s allegedly prejudicial statements to the jury, (4) the district court’s refusal to give an entrapment instruction, and (5) the district court’s application of a terrorism enhancement at sentencing.   The Fourth Circuit reversed the district court’s denial of the motion to dismiss Count Two, vacated the judgment, and remanded for resentencing. The court otherwise affirmed. The court concluded that Defendant’s false statements denying relevant knowledge could have influenced the FBI’s investigation. The court further wrote that Defendant claims the district court erred in applying the terrorism enhancement because it failed to expressly find specific intent. However, the court explained it need not delve into this question given that the court is remanding for resentencing because of the district court’s error on multiplicity. On remand, the district court can address the merits of Defendant’s claim regarding the terrorism enhancement. View "US v. Alexander Smith" on Justia Law

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Defendant Christina Banghart-Portillo pleaded guilty to tampering with evidence, and conspiracy to commit tampering with evidence, contrary to (Count 1 and Count 2, respectively), each of which was a fourth-degree felony offense, under a written plea agreement. Because Defendant had a prior felony conviction, each sentence was enhanced at her initial sentencing by one year under New Mexico’s habitual offender statute. Defendant also admitted her identity in a second prior felony at the time of her sentencing, yet the district court imposed no additional enhancement at that time. The district court imposed consecutive sentences. The central issue this case presented for the New Mexico Supreme Court's review was whether Defendant had a reasonable expectation of finality for Count 1 such that the district court no longer had jurisdiction when it applied the habitual offender enhancement to that Count. Defendant argued on appeal that the district court’s enhancement of the Count 1 sentence resulted in a double jeopardy violation because the court had lost jurisdiction by the time of the enhancement. The Court of Appeals held that the district court retained jurisdiction to apply a habitual offender enhancement to Count 1. The Supreme Court concluded Defendant did not have a reasonable expectation of finality in Count 1 at the time that the district court enhanced Defendant’s sentence because the district court had previously informed her of the consequences she faced if she violated probation. Therefore, it affirmed the Court of Appeals and held that the district court properly retained jurisdiction to apply a habitual offender enhancement to Count 1. View "New Mexico v. Banghart-Portillo" on Justia Law

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On three occasions, Harrison sold methamphetamine to B.B., a confidential informant who recorded the transactions on video. Police arrested Harrison. B.B. died before trial and was unable to testify about the controlled buys. As a substitute, the government played B.B.’s videos of the transactions for the jury, over Harrison’s objection. Recordings of statements from B.B. to law-enforcement personnel were excluded on Sixth Amendment grounds.The jury convicted Harrison on multiple drug counts and being a felon in possession of a firearm. The district court found that Harrison’s prior conviction for complicity to commit murder was a serious violent felony and that Harrison was subject to a sentencing enhancement, raising his mandatory minimum on the possession-with-intent-to-sell count from 10 years to 15. 21 U.S.C. 841. Harrison was sentenced to 15 years’ imprisonment. The Sixth Circuit affirmed, rejecting arguments that the introduction of B.B.’s videos violated his Sixth Amendment right to confront his accusers and the district court improperly characterized his prior conviction as a violent felony at sentencing. B.B.’s statements in the videos were not offered for their truth and were not hearsay. Complicity to commit murder always requires the use of physical force, because murder always requires the use of physical force. View "United States v. Harrison" on Justia Law

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In August, 1993, Fields, having spent the day drinking alcohol and smoking marijuana, got into a fight with Burton. Burton lived in a duplex owned by Horton. That night, Burton found that she was locked outside. Fields appeared, with a knife, and broke a window in the duplex. Both Fields and Burton fled before police arrived, having been called by a neighbor. Officers found Fields in Horton’s residence, a block away, in possession of Horton’s jewelry, saying that he had killed Horton, who was dead in her bedroom. At his second trial, the prosecution argued that Fields broke into Horton’s residence through a storm window, murdered her in the bedroom, and started burglarizing the residence shortly before police arrived. To test the plausibility of that theory, the jury conducted an experiment using a flat-tipped knife submitted into evidence to remove a cabinet door in the jury room (in place of the storm window). Satisfied with the outcome, the jurors convicted Fields of intentional murder and sentenced him to death.The Sixth Circuit granted Fields conditional habeas corpus relief. The jury improperly considered extrinsic evidence in violation of the Fifth and Sixth Amendments. Given the centrality of the issue, the inherently prejudicial nature of the experiment, and the lack of overwhelming evidence of guilt, the jury experiment had a “substantial and injurious effect or influence in determining the jury’s verdict.” View "Fields v. Jordan" on Justia Law

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Defendant served a 48-month sentence for use of interstate facilities to promote prostitution and began a three-year term of supervised release in October 2020. The district court first revoked supervised release on August 31, 2021, when Defendant admitted drug use and failure to participate in required drug counseling; Defendant began a 24-month term of supervised release that day.   His probation officer petitioned the court to issue a warrant, alleging numerous violations of supervised release. At the conclusion of a revocation hearing, the court found that Defendant committed the violations, revoked supervised release, and sentenced Defendant to 10 months’ imprisonment followed by 24 months of supervised release. Defendant appealed the revocation sentence, arguing the court violated his due process right to confront witnesses at the revocation hearing and imposed additional special conditions of supervised release that are substantively unreasonable.   The Eighth Circuit affirmed. The court explained that the facts recited in the warrant petition with the author present to testify, and Defendant’s testimony corroborating some of the alleged Grade C violations, including admissions he had not complied with sex offender registration requirements and had tested positive for cocaine use, were ample evidence supporting the district court’s decision to revoke supervised release. Further, the court found that the district court did not abuse its substantial discretion when it imposed additional conditions addressing what the court described as Defendant’s “high-risk behavior” and “continued disregard for the conditions imposed.” View "United States v. La'Ron Clower" on Justia Law

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Petitioner Li’Anthony Williams was 17 years old in 2001 when he pleaded guilty to assault in the second degree with sexual motivation and was sentenced under the indeterminate sentencing scheme for sex offenders. The trial court imposed the statutory maximum term of life with a minimum term at the bottom of the three to nine month standard range. Williams was transferred to the Department of Corrections (DOC) with the understanding that his release date would be determined by the Indeterminate Sentence Review Board (ISRB or Board). The ISRB found Williams was not releasable. Williams in turn filed a personal restraint petition (PRP) on grounds that his maximum term of life sentence was unconstitutional and that he was sentenced to a nonexistent crime. Williams also argued his petition was not barred by the one-year time limit for two reasons: (1) his claim was based on Washington v. Houston-Sconiers, 391 P.3d 409 (2017), which was a significant, material change of law that should be retroactively applied; and (2) his conviction was invalid on its face. The Washington Supreme Court disagreed with both claims: Williams’ petition failed to meet the time bar exception under RCW 10.73.100(6) because his sentence did not violate the substantive rule of Houston-Sconiers; therefore, Houston-Sconiers was not material to Williams’ claim. Furthermore, Williams’ petition did not meet the exception under RCW 10.73.090 because the State’s failure to specify the intended felony underlying the conviction on the judgment and sentence (J&S) did not render the J&S invalid on its face. The Court therefore dismissed Williams’ petition as untimely. View "In re Pers. Restraint of Williams" on Justia Law