Justia Criminal Law Opinion Summaries

Law enforcement identified an individual using the eMule peer-to-peer file-sharing platform who was sharing files with hash values matching those of known child pornography. The account was traced to the defendant, who had a prior record of offenses involving minors. Despite being unable to directly download the flagged files from the defendant’s account, agents matched the hash values and observed filenames indicative of child pornography. The officers obtained a search warrant, searched the defendant’s residence, and seized numerous electronic devices. Forensic analysis uncovered tens of thousands of images and hundreds of videos containing child pornography.The United States District Court for the District of Arizona reviewed several pretrial motions. The defendant moved to suppress evidence, arguing the search warrant lacked probable cause since agents had not visually confirmed the files’ content and that the review of his publicly shared files violated his Fourth Amendment rights and the Wiretap Act. The defendant also moved to dismiss the indictment, claiming prejudice from forensic analysis conducted without counsel present, and argued selective prosecution due to his status as a registered sex offender. Following hearings, the district court denied all motions. After a jury convicted the defendant on all counts, the court also denied his Rule 29 motion for judgment of acquittal, and sentenced him to concurrent prison terms and supervised release.The United States Court of Appeals for the Ninth Circuit affirmed the conviction. The court held that hash value matches, even without visual confirmation, provided probable cause to support the search warrant, especially when reinforced by descriptive filenames and the defendant’s criminal history. The court found no Fourth Amendment or Wiretap Act violations because the files had been made publicly available. It ruled there was no right to counsel during the non-critical stage of forensic analysis and found no evidence supporting selective prosecution. The court declined to review the sufficiency of the evidence claim due to lack of argumentation. View "USA V. JOHNSEN" on Justia Law

Police responded to a home after multiple 911 calls about a person experiencing a mental health episode. They found the defendant, Jamien Harris, agitated and naked with her hands through broken windows. Harris stated her grandmother was dead inside and claimed someone else had killed her. Officers discovered the body of Harris’s grandmother, who had died from a gunshot wound. Several firearms, including the murder weapon, were found in the home. Harris made conflicting statements to detectives, at times identifying herself as the shooter and at other times suggesting another family member was responsible. She was initially charged with criminal possession of a firearm based on evidence collected on November 21, the day after the murder.Harris pleaded guilty to two counts of criminal possession of a firearm in County Court, after a colloquy confirming she understood that a subsequent murder charge could be brought. Later, DNA evidence linked Harris to the murder weapon. The prosecution obtained a second indictment from a grand jury, charging Harris with murder in the second degree. Harris moved to dismiss the murder indictment under CPL 40.40(2), arguing that possession and murder charges should have been joined because they were part of the same criminal transaction. County Court granted the motion, dismissing the murder indictment.The Appellate Division reversed County Court’s dismissal, concluding the firearm possession and murder were separate and distinct criminal acts, not part of the same criminal transaction, and reinstated the murder indictment. The New York Court of Appeals reviewed the case and affirmed the Appellate Division’s order. The Court of Appeals held that the simple possession charge, based on Harris’s control of the firearm on November 21, was independent from the murder committed on November 20, and thus the murder prosecution was not barred by CPL 40.40(2). The court found no evidence of multiple or harassing prosecutions intended to violate the statute. View "People v Harris" on Justia Law

The defendant pleaded guilty to one count of second-degree assault in Seneca County Court, resolving two indictments, in exchange for a sentence of five years’ probation and the possibility of participation in the Monroe County Mental Health Treatment Court if recommended. However, it later became apparent that such a sentence was unlawful for a class D felony, and the defendant was not eligible for the treatment court. At the initial sentencing, the newly elected District Attorney, who had previously worked on the defendant’s case as an Assistant Public Defender, objected to the agreed-upon probation sentence. The defendant then moved to disqualify the District Attorney due to a conflict of interest. The court granted this motion, appointed as special prosecutor the former Assistant District Attorney who had negotiated the plea, and proceeded with sentencing.After the special prosecutor was appointed, the court made clear it would not impose straight probation and would consider only a lawful sentence, such as shock probation. The special prosecutor stated he was “fine with” shock probation, an alternative the defendant also requested, arguing it would fulfill his expectations under the plea agreement. The court repeatedly offered the defendant the opportunity to withdraw his plea, but he declined. Ultimately, the court imposed a four-year determinate prison sentence and three years of post-release supervision.The Appellate Division affirmed, concluding the prosecution had not violated the plea agreement, as the court determined the sentence was not appropriate and allowed the defendant to withdraw his plea. The New York Court of Appeals affirmed the Appellate Division’s order. The Court held that, under these unique circumstances—where the negotiated sentence was illegal, the District Attorney was disqualified, and the special prosecutor agreed to a lawful alternative that met the defendant’s expectations—vacatur and resentencing before a different judge were not required or warranted. View "People v Flesch" on Justia Law

The defendant was indicted in 2019 for theft by deception, accused of stealing $750,000 from investors who believed they were purchasing a 30 percent interest in a World of Beer franchise in Hoboken, when he actually owned only 5 percent. The funds were deposited into an account for his family’s business, and a state investigator testified that the money was used for personal and family expenses rather than for the franchise. A jury convicted the defendant in April 2023.Shortly after the verdict, the defendant moved for a new trial, claiming newly discovered evidence. At a hearing, his sister testified that she uncovered documents in their parents’ home after searching through boxes, and the defendant soon found electronic copies in his email. These included franchise agreements naming the family business as the sole franchisee and a document purporting to show the defendant’s 30 percent ownership in a related entity. The trial court granted a new trial, finding the evidence was not discoverable by reasonable diligence before trial due to the large volume of documents. The Appellate Division affirmed, deferring to the trial court’s findings.The Supreme Court of New Jersey reviewed the case. The Court held that the defendant failed to satisfy the requirement of reasonable diligence because he possessed the documents before trial, knew or should have known of their existence, and could have located them easily with basic searches. The Court found that it was an abuse of discretion for the lower courts to conclude otherwise. Additionally, the Court noted serious concerns about possible fraud involving the proffered documents, though it did not reach a final conclusion on that issue. The Supreme Court of New Jersey reversed the grant of a new trial and remanded the case for sentencing. View "State v. Patel" on Justia Law

A police officer in Fort Myers, Florida, observed Jddarrian Irons carrying a distinctive fanny pack and later found a handgun in it after stopping the car he was riding in. Irons, who had a prior felony conviction for attempted carjacking, was indicted for being a felon in possession of a firearm under federal law. He pleaded guilty to the charge.A probation officer prepared a presentence report recommending a base offense level of 20 under §2K2.1(a)(4)(A) of the Sentencing Guidelines, based on Irons’s prior conviction for a crime of violence, and a three-level reduction for acceptance of responsibility. The government, agreeing with most of the report, argued for a four-level enhancement under §2K2.1(b)(6)(B), contending Irons possessed the firearm in connection with the felony offense of carrying a concealed firearm under Florida law. The United States District Court for the Middle District of Florida adopted these recommendations, calculating a total offense level of 21 and imposing a sentence of 46 months in prison and three years of supervised release. The court also imposed special conditions of supervised release, including requirements to obtain a GED and submit to computer searches.The United States Court of Appeals for the Eleventh Circuit reviewed the case. The appellate court affirmed the district court’s calculation of the base offense level, holding that attempted carjacking qualifies as a crime of violence under the relevant Sentencing Guidelines, and that a four-level enhancement was appropriate because the firearm facilitated Irons’s concealed-carry offense. However, the appellate court vacated the conditions of supervised release requiring Irons to obtain his GED and to submit his computer to searches, ruling that these conditions were not properly pronounced at sentencing. The case was remanded for resentencing on those conditions. View "USA v. Irons" on Justia Law

Two major airline crashes in 2018 and 2019 involving Boeing 737 MAX aircraft led to the deaths of hundreds of passengers and crew. Investigations revealed that Boeing had concealed important safety information about modifications to the planes’ flight control system, contributing to the crashes. The Department of Justice (DOJ) charged Boeing with conspiracy to defraud the United States but later entered a Deferred Prosecution Agreement (DPA) in 2021, requiring Boeing to pay significant penalties and undertake compliance measures. After Boeing allegedly breached the DPA, the DOJ pursued a Non-Prosecution Agreement (NPA) in 2025, again imposing penalties and compliance obligations in exchange for dismissing the criminal charge. Family members of crash victims challenged both agreements, asserting violations of their rights under the Crime Victims’ Rights Act (CVRA).The United States District Court for the Northern District of Texas found that while the DOJ had originally failed to confer with families before the 2021 DPA due to a legal error, there was no bad faith, and the court lacked authority to modify or review the substance of the DPA or NPA. The district court later granted the DOJ’s motion to dismiss the prosecution against Boeing after the NPA, finding the DOJ’s actions were not in bad faith and were adequately explained.On appeal, the United States Court of Appeals for the Fifth Circuit held that the families’ challenge to the 2021 DPA was moot since the agreement was no longer in effect after Boeing’s breach. Addressing the NPA, the Fifth Circuit concluded the DOJ had fulfilled its obligation to confer with the families and had not misled them. The court also determined it lacked jurisdiction under the CVRA to substantively review the district court’s dismissal of the prosecution. The petitions for writ of mandamus were denied. View "Ryan v. USA" on Justia Law

In this case, the petitioner was convicted by a jury in Puerto Rico in 1996 for four counts of first-degree murder and related charges, stemming from a shooting known as the "Piñones Massacre." The prosecution’s case relied in part on the testimony of Regino Burgos-Torres, who implicated the petitioner in ordering the killings as revenge for the deaths of his brothers, allegedly at the hands of three of the victims. Many years later, the petitioner discovered that the prosecution had not disclosed affidavits from two eyewitnesses to his brothers’ murders. These affidavits implicated two other individuals and did not mention the three victims, potentially undermining the prosecution’s theory of motive.The petitioner sought a new trial in the Puerto Rico court, arguing that the suppression of the affidavits violated the rule established in Brady v. Maryland. The court denied his motion after holding an evidentiary hearing, finding that the affidavits would not have altered the verdict because what mattered was the petitioner’s belief about who killed his brothers, not who actually did. The intermediate appellate court and the Puerto Rico Supreme Court declined further review.The petitioner then filed a federal habeas corpus petition in the United States District Court for the District of Puerto Rico under 28 U.S.C. § 2254, presenting the same Brady claim. The district court dismissed the petition without reviewing key portions of the state court record, namely the trial testimony of Burgos-Torres. Upon remand from the United States Court of Appeals for the First Circuit to correct this error, the district court again denied relief without obtaining the necessary transcript or a narrative summary of the testimony.The United States Court of Appeals for the First Circuit vacated the district court’s judgment. The court held that the district court could not reasonably evaluate the state court’s adjudication of the Brady claim under § 2254 without the transcript or a narrative summary of Burgos-Torres’s testimony. The case was remanded with instructions to obtain that record and reconsider the petition accordingly. View "Crespo-Morales v. Caro-Delgado" on Justia Law

Jaron Starkey pleaded guilty to a federal drug-trafficking offense and was sentenced to 300 months in prison. His sentence was enhanced under the career-offender provision of the United States Sentencing Guidelines, based on two prior felony drug-distribution convictions in Delaware from 2012 and 2019. Starkey challenged the use of these convictions as predicates for the enhancement, contending that the Delaware statutes under which he was convicted criminalized attempted drug distribution, which, according to Fourth Circuit precedent prior to a 2023 Guidelines amendment, would not qualify as “controlled substance offenses” under the Sentencing Guidelines.The United States District Court for the Eastern District of Virginia rejected Starkey’s argument and applied the career-offender enhancement, concluding that his prior Delaware convictions qualified as predicate offenses under the Guidelines. Starkey appealed this determination.The United States Court of Appeals for the Fourth Circuit reviewed the case and affirmed the district court’s judgment. The Fourth Circuit held that the Delaware statutes under which Starkey was convicted define “delivery” to include “attempted transfers,” but this does not mean they criminalize attempted delivery as an inchoate offense. Instead, the offense of delivery encompasses completed acts that may include attempted transfers, which are distinct from mere attempts prosecuted under separate attempt statutes. The court found that Delaware law does not prosecute inchoate attempted deliveries under its drug-distribution statutes. Therefore, Starkey’s prior convictions properly qualified as controlled substance offenses for the career-offender enhancement. The Fourth Circuit affirmed the judgment of the district court. View "US v. Starkey" on Justia Law

The defendant pleaded guilty to a federal offense that prohibits possession of a firearm by a convicted felon. During sentencing, his presentence report recommended an enhanced base offense level because of a prior 2008 conviction under Virginia Code § 18.2-53.1 for using a firearm in the commission of a felony, specifically robbery. This enhancement was based on the conclusion that the prior conviction constituted a “crime of violence” as defined by the Federal Sentencing Guidelines. The defendant, through counsel, objected, arguing that his prior conviction did not meet the Guidelines’ definition of a crime of violence, and the parties’ written and oral arguments focused primarily on whether the elements clause or the enumerated offense clause of the Guidelines applied.The United States District Court for the Eastern District of Virginia overruled the defendant’s objection and applied the enhancement, basing its conclusion on the elements clause. The court’s reasoning mirrored the elements clause language, and its supporting citations were to cases addressing that clause or similar provisions. The resulting advisory Guidelines range was higher, and the defendant received a 33-month sentence. On appeal, he argued that the court erred in finding his prior conviction qualified as a crime of violence. The government defended the application of the elements clause and also raised arguments under the enumerated offense clause and harmless error doctrine.The United States Court of Appeals for the Fourth Circuit held that the district court erred in concluding the prior Virginia conviction satisfied the elements clause, adopting circuit precedent holding that Virginia robbery does not categorically require the use, attempted use, or threatened use of physical force against another. The Fourth Circuit found the government had not demonstrated harmless error and declined to affirm based on the enumerated offense clause. The court vacated the sentence and remanded for resentencing. View "US v. Scott" on Justia Law

The defendant was indicted for first-degree murder and several related offenses stemming from the killing of Keith Crump. He filed a motion under the Racial Justice Act to bar the death penalty, but the case proceeded as a capital trial. In December 2011, a jury convicted him on all counts, including first-degree murder, and recommended a death sentence, which the Superior Court of Stanly County imposed. The defendant appealed directly to the Supreme Court of North Carolina, as is standard in cases involving a death sentence.After his conviction, the defendant filed further motions under the Racial Justice Act and successfully moved to stay appellate proceedings in the Supreme Court of North Carolina, pending resolution of those motions. While the appeal was pending, he sought clemency from the governor. On December 31, 2024, the governor commuted his death sentence to life imprisonment without parole. The defendant then requested that the Supreme Court of North Carolina dissolve the appellate stay and remand his case to the North Carolina Court of Appeals, arguing that his case was no longer a capital case and thus should not be reviewed by the Supreme Court.The Supreme Court of North Carolina examined whether it retained jurisdiction for direct appeal under N.C.G.S. § 7A-27(a)(1) after the governor’s commutation. The court held that the statutory right to direct appeal to the Supreme Court exists to prevent arbitrary or unjust executions and applies only while a death sentence is active. Because the commutation eliminated the possibility of execution, the legislative intent underlying direct Supreme Court review no longer applied. Therefore, the court dissolved its stay and remanded the case to the Court of Appeals for review under the ordinary appellate procedure for non-capital cases. View "State v. Robinson" on Justia Law