Justia Criminal Law Opinion Summaries

In this case, the defendant was charged in 2022 with two counts of sexual abuse of a child, based on allegations by C.R. that the abuse occurred between 1988 and 1990. During the investigation, C.R. recalled being pulled out of class in seventh grade and questioned about the abuse. The defendant moved to dismiss the charges, arguing that the statute of limitations had expired because C.R.’s communication in seventh grade constituted a report to law enforcement, triggering the limitations period under the statute in effect at the time.The Third District Court for Salt Lake County held an evidentiary hearing on the motion. The State presented testimony from a detective and a records director, but no records of a report from the relevant period were found, and witnesses explained that recordkeeping practices at the time were inconsistent. The defense called former law enforcement officers who testified that not all reports were documented. The district court, relying on the Utah Court of Appeals’ decision in State v. Pierce, concluded that because the evidence was not clear enough to resolve the statute of limitations issue as a matter of law, the question should be submitted to the jury. The court denied the motion to dismiss and reserved the issue for trial.On interlocutory appeal, the Supreme Court of the State of Utah held that the district court erred by reserving the statute of limitations issue for the jury. The Supreme Court clarified that under Utah Code section 76-1-306, the judge—not the jury—must determine by a preponderance of the evidence whether a prosecution is time-barred. The court reversed the district court’s order and remanded the case for the district court to make the necessary factual findings and apply the correct legal standard. The Supreme Court left to the district court’s discretion whether to take additional evidence on remand. View "State v. Smith" on Justia Law

The appellant, a Marine Corps veteran with significant psychiatric disabilities, lived in Knox County, Kentucky, with his children and sister’s family. After separating from his wife, they began to reconcile, and he arranged to lease a second trailer, allegedly through an oral agreement with his landlord. An acquaintance, Deborah Powers, stayed in the trailer, but she claimed to have leased it with her boyfriend, Matthew Welsh. One night, after a party at the trailer, the appellant’s wife alleged she was raped by three men present. Instead of contacting police, the appellant, accompanied by two others, returned to the trailer armed, forcibly entered, and subjected the alleged assailants to threats, violence, and torture. During the confrontation, Welsh stabbed the appellant, who then fatally stabbed Welsh. The appellant was charged with murder, first-degree burglary, and four counts of unlawful imprisonment.The Knox Circuit Court conducted the trial. The appellant’s requests for self-defense and imperfect self-defense jury instructions were denied. The court admitted hearsay testimony regarding a rape kit and allowed a copy of a lease to be introduced over objections concerning the best evidence rule and authenticity. The appellant’s motion for his counsel to withdraw was also denied. The jury convicted him on all charges, and he was sentenced to thirty-five years in prison.The Supreme Court of Kentucky reviewed the case. It held that the trial court did not abuse its discretion in refusing self-defense instructions, as the appellant’s own actions created the deadly situation. The court found no palpable error in the admission of the rape kit testimony, as the error did not substantially affect the defense. However, it concluded that admitting the copy of the lease without proper foundation was an abuse of discretion, requiring reversal of the burglary conviction. The court affirmed the murder and unlawful imprisonment convictions and the overall sentence, remanding for amendment of the judgment to reflect the reversal of the burglary conviction. View "MASTERS V. COMMONWEALTH OF KENTUCKY" on Justia Law

Two individuals, Brandon Waddles and his three-year-old daughter, were killed in their home. The prosecution alleged that the defendant orchestrated the crime by having his girlfriend lure Waddles to the door, after which the defendant, driven to the scene by another accomplice, shot both victims. The defendant was indicted on two counts of murder, first-degree burglary, and being a felon in possession of a handgun. The prosecution’s case relied heavily on the testimony of the accomplices, both of whom had entered plea agreements in exchange for their cooperation.The case was tried in the Jefferson Circuit Court. During the trial, after one accomplice testified, the trial judge, outside the jury’s presence but in front of the media, ordered the witness taken into custody for perjury, stating that the witness had lied under oath. This event was reported by the media, and a juror saw the report, subsequently informing the rest of the jury. During deliberations, a juror reported being unable to decide the case truthfully after learning of the arrest. The defense moved for a mistrial, but the trial court denied the motion, instead excusing one juror and instructing the remaining jurors to disregard the information. The jury ultimately convicted the defendant of both murders and burglary, and he was sentenced to life without parole.On appeal, the Supreme Court of Kentucky held that the trial court erred by not granting a mistrial after the jury became aware that a key prosecution witness had been arrested for perjury at the judge’s direction. The court found that this extrajudicial information tainted the jury and constituted a structural error, depriving the defendant of a fair and impartial trial. The court vacated the convictions and remanded the case for further proceedings. View "LAWLESS V. COMMONWEALTH OF KENTUCKY" on Justia Law

The case concerns an individual who was arrested twice for suspicion of driving under the influence (DUI) in Pennsylvania. The first arrest led to charges, while the second arrest did not result in charges until several months later. In the interim, the individual applied for admission to the county’s Accelerated Rehabilitative Disposition (ARD) program for the first DUI. The ARD application required disclosure of prior convictions, prior ARD participation, and any pending criminal charges, but did not ask about uncharged arrests. The applicant truthfully stated he had no pending charges at the time of the application.After the applicant was admitted to the ARD program, the Commonwealth learned of the second DUI charge and moved to revoke his ARD participation, arguing he violated program conditions by not disclosing the prior arrest. The Adams County Court of Common Pleas revoked his ARD participation, initially citing the new charges and later referencing “deception by omission.” The applicant was subsequently convicted and sentenced for the first DUI. The Pennsylvania Superior Court affirmed, reasoning that failing to disclose the second arrest, even if uncharged, undermined the spirit and intent of the ARD program, and relied on prior cases where omissions or misrepresentations justified ARD revocation.The Supreme Court of Pennsylvania reviewed the case and held that revocation of ARD participation must be based on violation of a specified condition of the program, not on implied conditions or the general “spirit” of the program. The Court found that the applicant answered all questions on the ARD application truthfully, as there were no pending charges at the time, and the application did not require disclosure of uncharged arrests. Therefore, the trial court erred in revoking ARD participation, and the Supreme Court reversed the Superior Court’s decision. View "Commonwealth v. Jenkins" on Justia Law

A police officer applied for a search warrant for a residence based on information from a confidential reliable informant (CRI). The CRI reported that, within the previous 72 hours, they had visited the residence and observed people smoking methamphetamine and meth pipes inside. The CRI was not directed by law enforcement to visit the house and had a history of providing reliable information to the police. Based on this information, a district court judge issued a search warrant. When the warrant was executed, officers found drug paraphernalia and items testing positive for methamphetamine. The resident was charged with two drug-related offenses.The defendant moved to suppress the evidence, arguing that the warrant was not supported by probable cause. The Swift County District Court denied the motion, finding the warrant application sufficient. After a jury found the defendant guilty, the Minnesota Court of Appeals affirmed the conviction in a divided opinion. The majority held that the totality of the circumstances, including the CRI’s reliability and basis of knowledge, established probable cause, and rejected the argument that corroboration of the CRI’s tip was always required. The dissent argued that corroboration was necessary and that the lack of it meant probable cause was lacking.The Minnesota Supreme Court reviewed the case to clarify whether corroboration of a confidential reliable informant’s tip is an independent requirement for probable cause. The court held that corroboration is not an independent requirement but is always a relevant factor in the totality-of-the-circumstances analysis. Applying this standard, the court concluded that the limited, uncorroborated observations in the warrant application did not establish a fair probability that contraband or evidence of a crime would be found in the house at the time of the search. The court reversed the decision of the court of appeals and remanded the case for further proceedings. View "State of Minnesota vs. Nagle" on Justia Law

The appellant was convicted by a jury of three counts of first-degree murder and three counts of second-degree murder for the deaths of three individuals in 1995. He was sentenced in 1996 to three consecutive life sentences, as required by statute for first-degree murder. At the time of sentencing, a probation agent advised the court that a presentence investigation (PSI) would not affect the sentence because the law mandated life imprisonment. The appellant did not receive a PSI, and a post-sentence investigation was to be conducted by the Department of Corrections. Over the years, the appellant challenged his convictions and sentences through multiple postconviction petitions, all of which were denied.In 2024, the appellant filed a motion to correct or reduce his sentence under Minnesota Rule of Criminal Procedure 27.03, subdivision 9, arguing that the lack of a PSI and alleged errors in calculating his criminal history score rendered his sentences unlawful. The State argued that the motion was actually a postconviction petition subject to the two-year statute of limitations under Minnesota Statutes § 590.01, subdivision 4, and that the court lacked jurisdiction. The Carver County District Court agreed with the State, denied the motion, and stated it lacked jurisdiction, but did grant jail credit for time served.The Minnesota Supreme Court reviewed the case and held that the district court erred in concluding it lacked jurisdiction to hear the appellant’s motion under Rule 27.03, subdivision 9, because such motions are not subject to the statutory time bar and, even if they were, the time bar is not jurisdictional. However, the Supreme Court affirmed the district court’s denial of relief, holding that the appellant’s mandatory life sentences were lawful. The absence of a PSI and the alleged miscalculation of the criminal history score did not render the sentences unlawful, as neither the PSI statute nor the sentencing guidelines apply to mandatory life sentences for first-degree murder. View "Riley vs. State of Minnesota" on Justia Law

A former U.S. Navy Reserve officer, after serving in Afghanistan, maintained contact with an Afghan businessman who had provided interpreters to U.S. forces. In 2018, the businessman asked the officer to write letters of recommendation for Afghan nationals seeking Special Immigrant Visas (SIVs) to the United States, offering payment in return. The officer agreed, negotiating a price and ultimately producing multiple letters that attested to his personal knowledge of the applicants’ character and service, despite not actually knowing or remembering them. The letters were used in SIV applications, and the officer received payment, which he attempted to disguise as consulting fees through a false invoice.A grand jury in the United States District Court for the District of New Hampshire indicted the officer on four counts: conspiracy to commit bribery and false writing, bribery, false writing, and conspiracy to commit concealment money laundering. At trial, the officer moved for acquittal on the basis of insufficient evidence of falsity in the letters, but the district court denied the motion. The jury convicted him on all counts, and the district court later denied a renewed motion for acquittal, finding sufficient evidence for the jury to conclude the letters contained false statements and that the government was not required to prove falsity for all charges. The court sentenced the officer to thirty months’ imprisonment.On appeal, the United States Court of Appeals for the First Circuit reviewed the sufficiency of the evidence de novo and affirmed the convictions. The court held that there was sufficient evidence for a rational jury to find the letters contained false statements about the applicants’ character and the officer’s personal knowledge. The court also rejected challenges to the bribery and money laundering convictions, finding no clear or obvious error and no impermissible merger of offenses. The convictions and sentence were affirmed in full. View "United States v. Pittmann" on Justia Law

A defendant committed several serious offenses, including first-degree murder and attempted murder, when he was 17 years old. In 2002, a jury convicted him of these crimes, and he was sentenced to a total term of 79 years to life with the possibility of parole. The sentence included both determinate and indeterminate terms, with firearm enhancements. The crimes occurred in 2000, and the defendant was not sentenced to life without the possibility of parole (LWOP), but rather to a lengthy term that could be considered the functional equivalent of LWOP.Years later, the defendant filed a petition in the Superior Court of Ventura County seeking recall of his sentence under Penal Code section 1170, subdivision (d)(1)(A), which allows for resentencing of juvenile offenders sentenced to LWOP. The trial court granted the petition, reasoning that the defendant’s 79-year-to-life sentence was functionally equivalent to LWOP, relying on the reasoning in People v. Heard (2022) 83 Cal.App.5th 608 and People v. Sorto (2024) 104 Cal.App.5th 435. The court recalled the sentence, conditionally reversed the conviction and sentence, and certified the matter to juvenile court for further proceedings under Proposition 57. Meanwhile, the defendant received a youth offender parole hearing under Penal Code section 3051, but was found unsuitable for parole.The California Court of Appeal, Second Appellate District, Division Six, reviewed the case. It held that the defendant was not eligible for relief under section 1170(d)(1)(A) because he was not sentenced to LWOP, and that subsequent legislative changes, specifically section 3051, rendered the Heard rule moot. The court concluded that since the defendant had already received a parole hearing, he was not serving the functional equivalent of LWOP. The appellate court reversed the trial court’s orders. View "P. v. Lara" on Justia Law

The defendant was charged with resisting and obstructing an officer, domestic battery with corporal injury, and assault on a peace officer. During jury selection, the defendant sought to remove Juror 122 for cause due to the juror’s background in law enforcement and personal experience with domestic violence, but the Superior Court of Orange County denied the challenge for cause after Juror 122 stated he could remain impartial. The defendant then used a peremptory challenge to remove Juror 122, but the prosecution objected under Code of Civil Procedure section 231.7, arguing the challenge was based on impermissible grounds. The trial court sustained the objection, keeping Juror 122 on the panel. The jury ultimately convicted the defendant on one count, convicted him of a lesser included offense on another, and acquitted him on the third count.The Appellate Division of the Superior Court of California, County of Orange, reviewed the case. It reversed the conviction on one count but affirmed the judgment in all other respects. The Appellate Division held that the “deemed prejudicial” standard in section 231.7(j)—which requires automatic reversal if an objection to a peremptory challenge is erroneously denied—does not apply when an objection is erroneously granted. Instead, the court applied traditional harmless error analysis and found the defendant had not shown prejudice from Juror 122’s inclusion.The California Court of Appeal, Fourth Appellate District, Division Three, affirmed the Appellate Division’s judgment. The main holding is that the “deemed prejudicial” standard in section 231.7(j) applies only to erroneous denials of objections to peremptory challenges, not to erroneous grants. When an objection to a peremptory challenge is erroneously granted, traditional rules regarding prejudicial error govern, and automatic reversal is not required. View "P. v. Guzman" on Justia Law

In this case, law enforcement officers responded to a domestic disturbance at a residence where they found the defendant holding his pregnant fiancée by the wrists. The officers directed him to remain seated on the kitchen floor during their investigation, which lasted about forty minutes. During this time, the defendant was told he was not under arrest but was not free to leave. He eventually admitted to restraining his fiancée by the chin and neck and taking her to the ground. He was later arrested and charged with several offenses, including aggravated assault and battery.After a preliminary hearing in the Circuit Court, the case was bound over to the District Court of Albany County. The defendant moved to suppress statements made before his formal arrest, arguing they were obtained during a custodial interrogation without Miranda warnings. The State opposed, contending he was not in custody until his formal arrest. The District Court held a hearing, denied the motion to suppress, and accepted the defendant’s conditional guilty plea to aggravated assault, reserving his right to appeal the suppression ruling.On appeal, the Supreme Court of Wyoming reviewed whether the conditional guilty plea was valid under Rule 11(a)(2) of the Wyoming Rules of Criminal Procedure. The Court found that, although the plea was in writing, and both the State and the District Court approved it, the issue reserved for appeal—suppression of the defendant’s statements—was not dispositive. Independent evidence existed that could support conviction even if the statements were suppressed. Because the reserved issue was not dispositive, the conditional plea was invalid.The Supreme Court of Wyoming vacated the judgment of conviction and reversed and remanded the case to the District Court for further proceedings. The main holding is that a conditional guilty plea is invalid if the issue reserved for appeal is not dispositive of the entire case. View "Kotrc v. The State of Wyoming" on Justia Law