Justia Criminal Law Opinion Summaries

Jesse R. Redmond, Jr. was convicted by a jury of sexually assaulting his neighbor, B.R. Redmond later filed a motion to vacate his conviction, arguing that the government knowingly introduced false or misleading evidence by allowing an expert witness to testify that a hair found at the crime scene was consistent with his hair. Redmond contended that this testimony was material to the jury’s verdict.The Superior Court of the District of Columbia denied Redmond’s motion, agreeing with the government that the expert’s testimony was not material to the verdict. The court found that the testimony was brief, the prosecutor did not emphasize it in closing arguments, and there was overwhelming independent evidence of Redmond’s guilt, including B.R.’s identifications and Redmond’s own statements placing him at B.R.’s house.The District of Columbia Court of Appeals reviewed the case and concluded that the expert’s testimony was indeed material to the verdict. The court noted that the expert’s testimony was presented as authoritative and was the last evidence the jury heard before deliberations. The court also found that the other evidence of Redmond’s guilt was not overwhelming, as the jury had acquitted him on two of the three charges and had been deadlocked for some time. The court held that the government had not proven that the admission of the false or misleading testimony was harmless beyond a reasonable doubt.The court rejected the government’s argument that the more lenient harmless error standard from Brecht v. Abrahamson should apply to Redmond’s post-conviction motion. The court held that Napue violations, which involve the knowing presentation of false or misleading testimony, are reviewed for materiality under the stricter Chapman v. California standard and are not subject to further review for harmless error under Brecht. The court vacated Redmond’s conviction and remanded for a new trial. View "Redmond v. United States" on Justia Law

The appellant, Delvin T. Neal, was convicted of robbery in the Superior Court of the District of Columbia. Neal, a barber, had a long-standing client, Andrew Street, who sold watches. Neal purchased a Hublot watch from Street for $1,000, which was later found to be fake. Neal attempted to get a refund, but Street refused. Subsequently, Neal arranged to meet Street at his barbershop to discuss another watch. During this meeting, Neal assaulted Street and, with the help of two unknown men, took Street's watch, earrings, and chain. Neal also took Street's mother, Sillette Sheler's, wallet and refused to return it unless she paid him $1,000.The jury in the Superior Court found Neal guilty of robbing Sheler's wallet but acquitted him of robbing and assaulting Street. Neal appealed, arguing that the trial court failed to properly instruct the jury on the intent to steal and that he had a claim-of-right defense.The District of Columbia Court of Appeals reviewed the case. Neal contended that the jury instructions on intent to steal were inadequate. The court applied plain-error review and found no plain error, noting that the instructions given were sufficient and that Neal's actions demonstrated an intent to steal as he demanded $1,000 for the return of Sheler's wallet.Neal also argued that he should have been given a claim-of-right defense instruction, asserting he believed he had the right to take Sheler's wallet to recover his money. The court rejected this argument, holding that the claim-of-right defense does not apply when a defendant takes unrelated property to coerce payment of a debt.The court concluded that there was sufficient evidence to support Neal's conviction for robbery, as his actions met the criteria for intent to steal. The District of Columbia Court of Appeals affirmed Neal's conviction. View "Neal v. United States" on Justia Law

Marcus Ford was charged with several drug-related offenses after officers seized a vial of PCP and multiple baggies of cocaine from his pants pocket in his apartment building. Ford moved to suppress the evidence, arguing that he withdrew his initial consent to the search by putting his hand on his pocket as the officer touched a suspicious bulge. The trial court denied the motion, finding the encounter consensual until the drugs were seized.Ford appealed, and the District of Columbia Court of Appeals concluded that the trial court erred in ruling that Ford's actions did not revoke consent. The case was remanded for additional findings on whether the officer had a lawful basis for searching Ford's pocket. On remand, the trial court found that the search was supported by probable cause, citing the officers' experience, known drug activity in the building, and Ford's movements.In the current appeal, the District of Columbia Court of Appeals reviewed the trial court's denial of the motion to suppress. The court held that the trial court improperly considered Ford's revocation of consent as support for probable cause. The court emphasized that a suspect's exercise of the right to withdraw consent cannot be used to establish probable cause. Without considering the revocation of consent, the court found that the seizure of drugs was not justified under the plain feel doctrine, as the incriminating nature of the object was not immediately apparent to the officer.The District of Columbia Court of Appeals vacated Ford's convictions and remanded the case for further proceedings consistent with its opinion. View "Ford v. United States" on Justia Law

In 2019, Steven Rademacher was charged with murder, attempted murder, and terrorizing after driving his truck into a yard, killing one person and injuring others. He was found guilty by a jury, and the criminal judgments were affirmed on appeal. In 2023, Rademacher filed for postconviction relief, claiming ineffective assistance of counsel for not securing a complete vehicle examination and not obtaining an independent criminal responsibility evaluation.The District Court of Williams County held an evidentiary hearing where Rademacher's trial counsel testified. The court found no evidence suggesting the vehicle's brakes were defective and noted that Rademacher had not raised this issue with his counsel. The court also found that Rademacher's trial counsel had reviewed a criminal responsibility evaluation and decided against seeking a second independent evaluation. The court denied Rademacher's petition for postconviction relief.The North Dakota Supreme Court reviewed the case and affirmed the lower court's decision. The court held that Rademacher failed to demonstrate his trial counsel's performance fell below an objective standard of reasonableness regarding the vehicle examination. Additionally, the court found that Rademacher did not establish a reasonable probability that the outcome would have been different if a second independent criminal responsibility evaluation had been obtained. The court concluded that Rademacher did not meet the burden of proof required to show ineffective assistance of counsel. View "Rademacher v. State" on Justia Law

In 2002, the defendant was convicted of two counts of first-degree murder and sentenced to two concurrent life terms without parole. Following the 2024 decision in Commonwealth v. Mattis, which deemed life without parole for emerging adults unconstitutional, the defendant, who was 19 at the time of the crimes, sought resentencing to life with parole eligibility after 15 years and correction of his mittimus to reflect time served. The Commonwealth opposed and requested a hearing to determine if the sentences should be consecutive.The trial court granted the Commonwealth's request for a hearing, prompting the defendant to seek relief under G. L. c. 211, § 3. A single justice of the Supreme Judicial Court reserved and reported the matter to the full court.The Supreme Judicial Court of Massachusetts held that double jeopardy principles do not prevent resentencing the defendant to consecutive life terms with parole eligibility after 15 years. The court reasoned that such a change would not increase the aggregate punishment, as the original sentence was life without parole. The court also determined that a resentencing hearing is necessary to decide whether the sentences should be concurrent or consecutive, as the Mattis decision did not automatically alter the defendant's sentence.Additionally, the court ruled that the defendant is entitled to credit for time already served on each of the concurrent life sentences. Therefore, even if resentenced to consecutive terms, the defendant would be immediately eligible for parole, having already served over 23 years. The case was remanded for a resentencing hearing consistent with this opinion. View "Perez v. Commonwealth" on Justia Law

Auston McLain exchanged sexually explicit messages with an undercover FBI agent posing as a fifteen-year-old boy named Codey. McLain drove from Iowa to Illinois to meet Codey, where he was arrested with condoms and a cell phone containing the messages. A jury convicted McLain of attempted enticement of a minor and traveling with intent to engage in illicit sexual activity.The United States District Court for the Central District of Illinois excluded McLain's expert witnesses and certain testimony he wished to give. The court also addressed objections to the prosecutor's closing argument remarks and a jury instruction. McLain appealed, arguing these decisions denied him a fair trial.The United States Court of Appeals for the Seventh Circuit reviewed the case. The court found that the district court did not abuse its discretion in excluding the expert testimony, as it was not relevant to McLain's specific intent and could confuse the jury. The court also held that any error in excluding McLain's testimony about his past experiences was harmless, given the strong evidence against him. The prosecutor's remarks, while close to improper, did not deny McLain a fair trial. The jury instruction on intent was a correct statement of law and did not mislead the jury.The Seventh Circuit affirmed the district court's judgment, concluding that the cumulative effect of the alleged errors did not render the trial fundamentally unfair. The evidence overwhelmingly supported McLain's guilt, and none of the errors, individually or cumulatively, affected the verdict. View "United States v. McLain" on Justia Law

Jamal Antoine Williams was charged with promoting a criminal organization after standing watch while a gang leader spray-painted a gang-related message on public property and posing for pictures in front of the graffiti. The criminal organization in question was the Rollin 30s Crips, a set of the transnational gang known as the Crips. Williams admitted to previous membership in the Crips and was identified as a participant in the graffiti incident through video surveillance and social media posts.In the Circuit Court for Montgomery County, Williams waived a jury trial and pled not guilty with an agreed statement of facts. The court found him guilty of promoting a criminal organization under CR § 9-805 and sentenced him to five years’ incarceration, with all but six months suspended, followed by supervised probation. Williams appealed, and the Appellate Court of Maryland affirmed his conviction, interpreting "promote" broadly to include his actions.The Supreme Court of Maryland reviewed the case and held that CR § 9-805 is a general intent crime, requiring the State to prove that the defendant knew the organization was a "criminal organization" as defined by the statute. The court further held that the statute applies only to individuals who exercise a leadership role in the criminal organization or, if not members, exercise discretionary authority in connection with the act of promotion. The court found that the evidence was insufficient to prove that Williams had a leadership role or exercised discretionary authority in the gang. Consequently, the Supreme Court of Maryland reversed the conviction and directed the lower court to enter a judgment of acquittal. View "Williams v. State" on Justia Law

In February 2023, police officers arrested Charlie Vick for domestic assault and battery involving a firearm. After his arrest, officers discovered that the car he had been driving was uninsured, unregistered, and had invalid license plates. They waited until Vick's uncle attempted to drive the car away and then stopped him shortly after he exited the parking lot. The officers impounded the car and conducted an inventory search, which revealed a gun. Vick was subsequently charged with being a felon in possession of a firearm.The United States District Court for the District of Massachusetts ruled that the officers had staged the impounding and that their sole motive for the search was investigatory. Consequently, the court ordered the suppression of the evidence found during the search. The government appealed, arguing that the district court should not have considered the officers' subjective motives and that the court's finding of a sole investigatory motive was clearly erroneous.The United States Court of Appeals for the First Circuit reviewed the case. The court agreed with the government that the district court's finding of a sole investigatory motive was clearly erroneous. The appellate court noted that the officers had an objectively reasonable basis for impounding the car, as it was unregistered, uninsured, and had invalid plates, making it a safety hazard. The court also found that the officers' decision to impound the car was lawful under the community caretaking exception to the Fourth Amendment's warrant and probable cause requirements. Consequently, the appellate court reversed the district court's grant of the motion to suppress and remanded the case for further proceedings. View "US v. Vick" on Justia Law

Two cousins, Jairo Huertas-Mercado and Erick Pizarro-Mercado, were involved in a series of violent crimes in Puerto Rico, including six carjackings and two kidnappings, one of which resulted in death. The crimes occurred between May and June 2018, and involved the use of firearms and threats of violence. The victims included a security guard, a family on a road trip, a surfer, a couple, a churchgoer, and a well-known local singer, Bryant Myers, who was kidnapped along with his mother.The case was first brought to the United States District Court for the District of Puerto Rico, where Huertas was initially indicted in July 2018. Over time, the indictment was superseded three times, adding more charges and defendants, including Pizarro. The pretrial process was prolonged due to ongoing investigations, plea negotiations, and the COVID-19 pandemic. The death penalty review process also contributed to the delay. Ultimately, the trial began in September 2022, more than four years after the initial indictment.The United States Court of Appeals for the First Circuit reviewed the case. Huertas argued that his constitutional right to a speedy trial was violated due to the 51-month delay between his indictment and trial. The court applied the Barker v. Wingo balancing test and found that while the delay was lengthy, it was justified by valid reasons, including the complexity of the case, the need for thorough investigation, and the impact of the pandemic. Huertas' failure to assert his right to a speedy trial and the lack of demonstrated prejudice to his defense also weighed against him.Both defendants challenged the sufficiency of the evidence for their convictions, particularly the carjacking charges. The court found that the evidence, including witness testimonies and admissions by Huertas, was sufficient to support the jury's verdict. The court also rejected Huertas' double jeopardy claim, noting that the lesser included offense was dismissed before sentencing.Finally, Pizarro's argument that his life sentence was unreasonable was reviewed. The court found that the sentence was within the guideline range and justified by the severity of the crimes, affirming the district court's decision. The appeals court ultimately affirmed the convictions and sentences of both defendants. View "US v. Huertas-Mercado" on Justia Law

A former Baltimore police officer, Christopher Nguyen, was charged with reckless endangerment for failing to prevent an assault on Wayne Brown by Kenneth Somers. Nguyen arrived at the scene to find Brown injured and Somers admitting to the assault. While Nguyen was investigating, Somers kicked Brown in the head. Nguyen was charged for not preventing this spontaneous assault.In the Circuit Court for Baltimore City, Nguyen was convicted of reckless endangerment after a bench trial. The court found that Nguyen had a duty to protect Brown and that his failure to prevent the assault was a gross departure from the standard of conduct expected of a reasonable officer. The Appellate Court of Maryland affirmed the conviction, holding that Nguyen had a duty to protect Brown as a member of the public and that his conduct constituted reckless endangerment.The Supreme Court of Maryland reviewed the case. The court held that the State failed to prove that Nguyen had a legal duty to protect Brown from an unforeseeable assault by Somers. The court noted that the common law duties of police officers do not extend to protecting individuals from spontaneous and unforeseeable assaults by third parties. Additionally, the court found that the State did not establish a special relationship between Nguyen and Brown that would create a duty to protect. Consequently, the Supreme Court of Maryland reversed the judgment of the Appellate Court, finding that the State did not meet its burden of proving a legal duty under the circumstances. View "Nguyen v. State" on Justia Law