Justia Criminal Law Opinion Summaries

A five-year-old child died after being left in the care of the defendant, who was the only adult present at the time. The defendant called 911, reporting the child had fallen down the stairs and was unresponsive. Emergency responders observed significant bruising and signs of oxygen deprivation. The child was transported to a hospital and died the next day. Law enforcement, suspecting abuse, interviewed the defendant at the police station. The defendant was advised of her Miranda rights, acknowledged understanding them, and agreed to speak with officers. Over several hours, during which she was allowed breaks and was not under arrest, the defendant ultimately confessed to beating the child and admitted fabricating the story about a fall.The State charged the defendant with first-degree murder and child abuse. The defendant moved to suppress her confession, arguing it was involuntary due to custodial circumstances, her use of prescription medication, and an invalid Miranda waiver. The District Court of Lincoln County held a suppression hearing without the defendant present, as she was hospitalized, and her counsel consented to proceeding in her absence. The court found the confession voluntary, denied the suppression motion, and admitted the confession at trial. The jury convicted the defendant on both charges.On appeal, the Supreme Court of the State of Wyoming reviewed whether the district court erred in finding the confession voluntary and in conducting the suppression hearing without the defendant present. The Supreme Court held that, under the totality of the circumstances, the confession was voluntary and not the result of coercion or impairment. The court also found that any error in holding the suppression hearing without the defendant was harmless, as there was no reasonable probability her presence would have changed the outcome. The convictions and rulings of the district court were affirmed. View "Marler v. The State of Wyoming" on Justia Law

In the early morning hours of September 17, 2024, police responded to a report that a man had drawn a knife and approached a woman in her vehicle at a Fargo gas station. Surveillance video captured the incident, and Shawn King was apprehended near the scene. He was charged with terrorizing, carrying a concealed weapon, and possession of drug paraphernalia, though the drug paraphernalia charge was dismissed before trial. At trial, the victim testified that King approached her on a bicycle, threw it down, brandished a knife, and advanced toward her in an angry manner, causing her to fear for her safety. The jury viewed the surveillance footage and heard testimony from three officers. Ultimately, the jury found King guilty of terrorizing but acquitted him of carrying a concealed weapon.Following the jury’s verdict, the District Court of Cass County, East Central Judicial District, entered judgment and sentenced King to five years, with four years to be served and one year suspended during two years of supervised probation. King appealed, arguing that the terrorizing statute was unconstitutionally vague and overbroad as applied to his conduct, and that the combination of the terrorizing and concealed weapon statutes violated his right to lawfully carry a weapon. He did not raise these constitutional arguments in the district court.The Supreme Court of North Dakota reviewed King’s claims for obvious error, as they were not preserved below. The court held that King failed to demonstrate any clear or obvious deviation from current law regarding the constitutionality of the statutes as applied to him. The court found that the terrorizing statute incorporates both subjective and objective standards, and that King’s overbreadth and Second Amendment arguments did not establish plain error. The Supreme Court of North Dakota affirmed the district court’s judgment. View "State v. King" on Justia Law

The case concerns a defendant who was convicted by a jury of multiple sexual offenses, including rape, against his young daughter. The central issue on appeal relates to the jury selection process, specifically whether the defendant’s trial counsel was constitutionally ineffective for failing to challenge a particular juror, referred to as Juror McCarthy, for cause. During voir dire, Juror McCarthy expressed some initial uncertainty about his ability to be impartial in a case involving a child witness and indicated discomfort with the presumption of innocence, but also participated in group responses affirming his willingness to be fair and follow the law.After conviction, the defendant appealed to the Twelfth District Court of Appeals, arguing that his counsel’s failure to challenge Juror McCarthy deprived him of a fair trial. The appellate court reviewed the voir dire transcript and concluded that Juror McCarthy’s statements reflected an internal struggle common to many jurors faced with difficult subject matter, rather than actual bias against the defendant. The court also noted that Juror McCarthy, through group responses and direct questioning, indicated he could be fair and impartial. The appellate court therefore rejected the ineffective assistance claim and affirmed the convictions.The Supreme Court of Ohio reviewed the case, focusing on whether a reviewing court may consider group answers during voir dire when determining actual juror bias, and whether a juror who expresses partiality can be rehabilitated through such group responses. The court held that, in assessing actual bias, the entire voir dire record—including group answers—must be considered. The court found that the defendant failed to demonstrate that Juror McCarthy was actually biased, and thus did not establish ineffective assistance of counsel. The Supreme Court of Ohio affirmed the judgment of the Twelfth District Court of Appeals. View "State v. Rogers" on Justia Law

The defendant was charged with multiple counts of sex trafficking and coercion or enticement of prostitution, each count relating to one of four women he managed as a pimp over several years. The women testified that the defendant controlled their earnings, provided necessities, and used physical abuse, threats, and manipulation—including withholding drugs—to force or coerce them into commercial sex acts. Some victims also described having their identification taken and being compelled to travel interstate for sex work. The government’s case included testimony from the victims, law enforcement officers, and documentary evidence such as online advertisements and social media posts.The United States District Court for the Southern District of Texas presided over the trial. During the proceedings, the defense moved for a mistrial or to exclude certain witness testimony, arguing that the government failed to disclose text messages between an investigator and a victim, in violation of Brady v. Maryland and the Jencks Act. The district court denied these motions, allowed the contested testimony, and also denied the defendant’s motions for judgment of acquittal and a new trial. The jury convicted the defendant on all but one count, and the court sentenced him to 480 months’ imprisonment.On appeal, the United States Court of Appeals for the Fifth Circuit reviewed the sufficiency of the evidence de novo and found it sufficient to support the convictions. The court held that the missing text messages were not material under Brady or the Jencks Act, as their content was cumulative of other impeachment evidence. The court also found no reversible error in the admission of certain testimony and Instagram posts, concluding that any evidentiary errors were either harmless or not present. The Fifth Circuit affirmed the district court’s judgment in all respects. View "United States v. Lewis" on Justia Law

The case concerns an altercation that occurred after Jeffrey Burrington, while driving with his wife, began tailgating another vehicle driven by Ryan Williams. After both vehicles stopped, a verbal confrontation ensued, during which Burrington punched Williams in the face. Williams subsequently sought medical attention and was diagnosed with a fractured mandible, which required him to maintain a liquid diet for six weeks and limited his ability to perform certain job duties as a smokejumper. Burrington was charged with Aggravated Assault, a felony, and the State also proposed a jury instruction for the lesser included offense of Assault.In the Fourth Judicial District Court for Missoula County, Burrington moved to dismiss the case, arguing that Williams did not suffer a serious bodily injury and that he acted in self-defense. The District Court denied the motion, finding these were issues for the jury. At trial, Burrington presented a dual defense: justifiable use of force and lack of serious bodily injury. The jury heard testimony from Williams, medical experts, and both Burrington and his wife regarding prior incidents that shaped their perception of threat. After the State rested, Burrington moved for a directed verdict, which the District Court denied, concluding that the evidence was sufficient for the jury to decide.The Supreme Court of the State of Montana reviewed whether the District Court erred in denying the motion for a directed verdict, whether plain error review was warranted for unobjected-to trial incidents, and whether cumulative error required a new trial. The Supreme Court held that a rational jury could find Williams’s six-week mandibular injury constituted a “protracted loss or impairment” and thus a serious bodily injury under Montana law. The Court also found no plain error or cumulative error warranting reversal. The conviction and sentence were affirmed. View "State v. Burrington" on Justia Law

The case concerns a defendant who was convicted of first degree murder by torture and assault causing the death of a child. The prosecution’s theory was that the defendant either directly committed the crimes or aided and abetted his codefendant, the child’s mother, in committing them. The jury was instructed only on murder by torture and aiding and abetting, not on felony murder or the natural and probable consequences doctrine. The jury found the defendant guilty of first degree murder and assault causing death of a child, but a special circumstance finding was later reversed on appeal due to insufficient evidence of specific intent to kill.After the California Court of Appeal reversed the special circumstance finding but otherwise affirmed the judgment, the trial court resentenced the defendant. Following the enactment of Senate Bill 1437, which limited certain theories of murder liability and created a resentencing procedure under Penal Code section 1172.6, the defendant petitioned for resentencing. He argued that the jury instructions permitted conviction on an impermissible theory of imputed malice. The Napa County Superior Court denied the petition at the prima facie stage, finding the defendant had not shown he could not be convicted of murder under the amended statutes.The California Court of Appeal, First Appellate District, Division Two, reviewed the denial. The court held that the record conclusively established the defendant’s ineligibility for relief under section 1172.6 because he was convicted under a theory of murder—murder by torture, either as a direct perpetrator or as an aider and abettor—that remains valid after Senate Bill 1437. The court found that any alleged instructional error did not relate to changes made by the new law and affirmed the trial court’s order denying resentencing. View "People v. Warner" on Justia Law

The case concerns a woman who was charged, along with a codefendant, with the murder of her young daughter, with the special circumstance of torture, and with assault resulting in the death of a child under eight. The prosecution’s theory was that the murder was committed by torture, and that the defendant either directly committed the crimes or aided and abetted her codefendant. The jury was not instructed on felony murder or the natural and probable consequences doctrine; the only theory presented was murder by torture. The jury found the defendant guilty of first degree murder by torture and assault causing death of a child. On direct appeal, the special circumstance finding was reversed for insufficient evidence of specific intent to kill, but the murder conviction was affirmed based on evidence of deliberate and premeditated intent to cause extreme pain for a sadistic purpose.After the passage of Senate Bill 1437, which amended California’s murder statutes to eliminate certain forms of accomplice liability and created a resentencing procedure for those convicted under now-invalid theories, the defendant petitioned for resentencing under Penal Code section 1172.6. The Superior Court of Napa County denied the petition at the prima facie stage, finding the defendant ineligible for relief because she was not convicted under any theory affected by the statutory changes. The defendant appealed this denial.The California Court of Appeal, First Appellate District, Division Two, reviewed the case and affirmed the trial court’s order. The appellate court held that the record conclusively established the defendant’s ineligibility for relief under section 1172.6, as she was convicted solely under a theory of murder by torture, which remains a valid basis for murder liability after Senate Bill 1437. The court found that any alleged instructional error did not relate to the statutory changes and thus could not support resentencing relief under section 1172.6. View "People v. Krueger" on Justia Law

The case concerns a defendant who, while under the influence of methamphetamine, set fire to his sister’s doorbell and started another fire in the street. He was charged with arson of an inhabited structure and had a prior strike conviction. The defendant sought mental health diversion, presenting evidence of bipolar disorder and substance abuse disorder, and a mental health professional recommended residential treatment. The court initially granted diversion on the condition that the defendant be accepted into a residential treatment program. However, due to issues with Medi-Cal coverage and facility requirements, the defendant was unable to secure placement in the recommended residential program.After it became clear that residential treatment was not available, the defendant requested to participate in an intensive outpatient program with housing at a room and board facility, but the Superior Court of Sacramento County denied this request, citing concerns about public safety and the need for residential treatment as a condition precedent for diversion. The court then set aside the grant of diversion, without prejudice to reconsideration if a suitable residential program became available. The defendant later moved for public funding for private residential treatment, but the court denied the motion, explaining it lacked authority to order such funding after Medi-Cal declined coverage.On appeal, the California Court of Appeal, Third Appellate District, held that the trial court did not abuse its discretion in terminating mental health diversion when the required residential treatment was unavailable. The appellate court also held that Penal Code section 1001.36 does not require a trial court to order public funding for private treatment when existing public programs decline coverage. The judgment of the trial court was affirmed. View "People v. Riddle" on Justia Law

Andrew Maurice Randolph was convicted in Michigan state court of second-degree murder and weapons offenses after a shooting at his former girlfriend’s home resulted in the death of her mother. The prosecution’s case relied heavily on ammunition found in Randolph’s bags at his father’s house and a firearm discovered at his brother’s residence, which was identified as the murder weapon. Randolph’s trial counsel did not move to suppress this evidence, and Randolph argued that this failure, among other alleged deficiencies, constituted ineffective assistance of counsel.Following his conviction, Randolph appealed to the Michigan Court of Appeals, which rejected his ineffective assistance claim without explanation. The Supreme Court of Michigan reversed in part for unrelated reasons and remanded. On remand, the Michigan Court of Appeals affirmed the conviction, finding Randolph did not demonstrate a reasonable expectation of privacy in the searched belongings. The Supreme Court of Michigan denied leave to appeal. Randolph then sought federal habeas relief in the United States District Court for the Eastern District of Michigan, raising four ineffective assistance claims. The district court denied the petition, concluding that the suppression motion would have failed and that counsel’s other actions were either strategically reasonable or not prejudicial. The district court also denied a certificate of appealability (COA).On appeal, the United States Court of Appeals for the Sixth Circuit reviewed only the claim that trial counsel was ineffective for failing to move to suppress evidence obtained from the search of Randolph’s belongings, as this was the sole issue for which a COA was granted. The Sixth Circuit held that the state court’s factual findings and legal conclusions were reasonable under the Antiterrorism and Effective Death Penalty Act (AEDPA) and affirmed the district court’s denial of habeas relief. The court also denied Randolph’s request to expand the COA, holding that a merits panel lacks authority to do so. View "Randolph v. Macauley" on Justia Law

An employee of a telecommunications company, who also served as a union representative, was charged with defrauding a pharmacy benefits management company by orchestrating the submission of fraudulent claims for compounded medications. The government alleged that he induced another individual to obtain medically unnecessary compounded drugs and arranged for a doctor to sign prescriptions without a medical examination or determination of necessity. The prescriptions were then used to submit claims to the company’s health plan, and the employee received a percentage of the reimbursement. The government further alleged that the employee paid the individual to participate in the scheme and later instructed him to lie to investigators.The United States District Court for the District of New Jersey granted the defendant’s motion to dismiss the superseding indictment. The court found that the indictment failed to allege any actionable misrepresentation or omission under 18 U.S.C. § 1347, did not specify how the fraudulent claims were submitted or by whom, and did not identify any false statements or omissions in the claims. The court also expressed concern about the use of the term “medically unnecessary,” finding it vague and undefined.On appeal, the United States Court of Appeals for the Third Circuit reviewed the sufficiency of the indictment de novo. The Third Circuit held that the indictment adequately alleged an implicit misrepresentation: that the prescriptions, incorporated into the claims, falsely implied medical necessity and a legitimate doctor-patient relationship. The court found that such implicit misrepresentations are actionable under the health care fraud statute. The court also determined that the indictment’s language was sufficiently clear to apprise the defendant of the charges. Accordingly, the Third Circuit reversed the District Court’s dismissal and remanded the case for further proceedings. View "USA v. Mattia" on Justia Law