Justia Criminal Law Opinion Summaries

Frederick Lewis Moncrea was charged with multiple drug and firearm offenses. Pursuant to a plea agreement, he was convicted of two counts of possession with intent to distribute a Schedule I or II controlled substance and one count of possession of a firearm by a felon. As part of the agreement, Moncrea received a 25-year sentence with 22 years suspended, along with a period of supervised probation. The sentencing order entered by the trial court stated that Moncrea would be on supervised probation “until released by the Court or Probation Officer,” without specifying a precise duration.Moncrea did not object to the language regarding the duration of supervised probation before the trial court. He later appealed to the Court of Appeals of Virginia, arguing that the sentencing order was void ab initio because it imposed a period of supervised probation that could exceed the five-year maximum allowed by Code § 19.2-303. The Court of Appeals agreed with Moncrea, holding that any supervised probation beyond five years was void ab initio, as courts have no authority to impose probation conditions outside the parameters set by statute.The Supreme Court of Virginia reviewed the case. It held that the trial court’s sentencing order was not erroneous and did not violate the statutory limitation, as Code § 19.2-303 gives the court discretion to determine the conditions of probation so long as the period does not exceed five years. The Supreme Court found no evidence that Moncrea was, or would be, subject to supervised probation beyond the statutory maximum. Therefore, it did not reach the question of whether the sentencing order was void ab initio or merely voidable. The Supreme Court of Virginia reversed the judgment of the Court of Appeals and reinstated the sentence imposed by the trial court. View "Commonwealth v. Moncrea" on Justia Law

In May 2022, the appellant shot and killed a man at a St. Paul light-rail station. Surveillance video captured the incident, showing an argument followed by the appellant loading a gun and shooting the victim multiple times at close range. The appellant was arrested and charged with second-degree intentional murder, later indicted for first-degree premeditated murder and ineligible possession of a firearm.The case was first heard in the Ramsey County District Court. The appellant requested substitute counsel several times, citing conflicts of interest and alleged ineffective assistance, but the court denied these requests after inquiring into the claims and finding no exceptional circumstances. The appellant also sought to represent himself and, after a waiver colloquy, the court found his waiver of counsel to be knowing, intelligent, and voluntary. The appellant represented himself briefly at trial before requesting that standby counsel resume representation. The jury found him guilty on all counts, and the court sentenced him to life imprisonment without the possibility of release for first-degree murder.On direct appeal, the Minnesota Supreme Court reviewed whether the district court erred in denying substitute counsel, whether the waiver of counsel was constitutionally valid, and considered various other claims raised by the appellant. The court held that the district court conducted a sufficient inquiry into the allegations underlying the requests for substitute counsel and properly denied them, as no exceptional circumstances were shown. The court also concluded the appellant’s waiver of counsel was valid. Additional claims raised by the appellant were found to lack merit. The Minnesota Supreme Court affirmed the convictions and sentences imposed by the district court. View "State of Minnesota vs. Tillman" on Justia Law

The case concerns a criminal defendant who was convicted of first-degree murder, felony drive-by shooting, and being an ineligible person in possession of a firearm. The charges stemmed from a 2021 shooting outside a bar in Saint Paul, Minnesota, where one victim died and another survived. Police investigation connected the defendant to the crime through evidence including gunshot residue on his vehicle and ammunition found in his apartment. The defendant was initially successful in having certain firearm and ammunition evidence excluded, but later, as part of his trial strategy, he sought to admit that same evidence. The district court clarified on the record the scope of the evidence to be admitted and required the defendant’s personal consent before proceeding.After a jury trial, the defendant was acquitted of first-degree premeditated murder but convicted of first-degree murder while committing a drive-by shooting and related charges. The district court imposed sentences, including life with the possibility of release after 30 years. The Supreme Court of Minnesota affirmed the convictions on direct appeal, rejecting arguments about probable cause, the validity of the search warrant, evidentiary rulings, and confrontation rights.The defendant subsequently filed a pro se postconviction petition, alleging that the district court judge was not impartial due to purported advocacy for the prosecution and conducting independent research. The postconviction court summarily denied the petition without a hearing, finding the claims meritless and procedurally barred.The Supreme Court of Minnesota reviewed the summary denial for abuse of discretion and considered the legal question of judicial impartiality de novo. It held that the defendant failed to demonstrate that the judge was partial or that an objective observer would question the judge’s impartiality. The court affirmed the district court’s denial of postconviction relief. View "Glover vs. State of Minnesota" on Justia Law

After an argument at an apartment, Deon Andre Jennings was charged with the murder of Willie Houston. During the confrontation, Houston asked Jennings to leave several times, but Jennings refused. When Houston stepped outside, Jennings attempted to lock him out, but Houston forced his way back in, ending up on top of Jennings. While on the floor, Jennings struck Houston in the back multiple times with an object. Houston left the apartment, sought help, and later died from deep stab wounds. Jennings claimed self-defense, asserting he struck Houston only to get him off, not to kill him, and that he did not know what object he used.The Third District Court, Salt Lake County, conducted a pretrial justification hearing under Utah Code section 76-2-309, which allows for an evidentiary hearing on self-defense before trial. Jennings argued that a written proffer of facts was sufficient to make a prima facie claim of justification, while the State contended evidence was necessary. The district court found that a proffer alone was not enough; it considered both Jennings’ proffer and his attached exhibits. The court determined that Jennings’ evidence did not support a claim that he reasonably believed force was necessary to defend himself, and found that Houston had not threatened or physically assaulted Jennings.The Supreme Court of the State of Utah affirmed the district court’s ruling. It held that, to make a prima facie claim of justification under the statute, a defendant must present evidence at the hearing that, if believed, would be legally sufficient to satisfy each element of a justification defense. This is a burden of production, not of proof. Because Jennings failed to present evidence indicating he subjectively believed the force he used was necessary for self-defense, the denial of his motion to dismiss was affirmed. View "State v. Jennings" on Justia Law

The defendant pleaded guilty in 2010 to conspiracy to distribute and possess with intent to distribute a large quantity of cocaine base, for which he was sentenced to a lengthy prison term and a supervised release period. His sentence was later reduced under the First Step Act, resulting in a shorter prison term and an eight-year supervised release. After his release, the defendant demonstrated significant rehabilitation, complied with all conditions of supervision, and maintained steady employment and a stable residence, with no new criminal conduct.Following his positive adjustment, the defendant filed three separate motions in the United States District Court for the Eastern District of Tennessee seeking early termination of his supervised release. The district court denied the first motion, acknowledging his model behavior but emphasizing the seriousness of his offense and the statutory minimum term. The second motion was denied based solely on the judge’s custom of not considering early termination until at least half of the supervised release term had been served. After appealing this denial, the defendant filed a third motion, which the district court also denied, reiterating the importance of its fifty-percent custom and referencing deterrence and public safety.The United States Court of Appeals for the Sixth Circuit reviewed the consolidated appeals. The court held that the district court abused its discretion by employing a blanket rule requiring completion of at least half the supervision term before considering early termination, instead of conducting an individualized assessment under the relevant statutory factors in 18 U.S.C. § 3553(a) and § 3583(e)(1). The appellate court concluded that the district court’s reliance on its custom, without adequate consideration of the defendant’s circumstances and the statutory factors, was improper. The Sixth Circuit vacated the district court’s orders and remanded for further proceedings. View "United States v. Collins" on Justia Law

Two brothers operated an energy-conservation contracting business and, beginning in 2013, engaged in a bribery scheme involving the Mass Save program, a state-mandated initiative to promote energy efficiency. One brother owned CAP Electric, Inc., and recruited the other to establish Air Tight Solutions, LLC as a Mass Save contractor with the assistance of a CLEAResult employee, who was responsible for selecting and overseeing contractors. The brothers paid this employee, and later another, regular bribes in cash and gifts to secure contracts, favorable treatment, and advance warning of audits. Air Tight performed little or no work directly, subcontracted projects, and disguised employees and payments to conceal the scheme. Over several years, their companies received multi-million dollar payments from the program.The United States District Court for the District of Massachusetts accepted their guilty pleas to conspiracy, honest-services wire fraud, making false statements, and (for one brother) aiding and assisting false tax returns. The district judge sentenced both to 27 months in prison (above-guidelines for one), and ordered forfeiture of $13.2 million and $3.6 million respectively. The brothers challenged the sentences and forfeitures on several grounds, including alleged errors in calculating tax loss, application of sentencing enhancements, and the process and proportionality of the forfeiture orders.The United States Court of Appeals for the First Circuit reviewed the case. It held that the district court did not err in calculating tax loss or applying sentencing enhancements for sophisticated means, obstruction of justice, and aggravating role. The appellate court also held that the district court correctly found a sufficient connection between the criminal conduct and the forfeited proceeds, and that any procedural errors in the forfeiture process were harmless. Finally, the court determined that the forfeiture orders were not unconstitutionally excessive. The First Circuit affirmed the sentences and forfeiture orders. View "United States v. Ponzo" on Justia Law

The case involves Michael Donnell Lee, who was charged with murder and related offenses following the shooting death of Aaron James Grant. After his arrest, Lee underwent a custodial interrogation by Detective Charles Sendling of the Atlanta Police Department, during which Lee made incriminating statements. Prior to making these statements, Lee invoked his rights to counsel and to remain silent after being read his Miranda rights. The detective, after a brief pause and some procedural activity, re-engaged Lee in conversation, during which Lee ultimately agreed to talk and then made several incriminating statements during the ensuing interview.Before trial, the State moved to admit Lee’s statements, but the Superior Court of Fulton County excluded them, ruling that they were inadmissible under Miranda v. Arizona and Edwards v. Arizona because Lee had invoked his constitutional rights and had not reinitiated communication with the police. The trial court also found the statements to be involuntary as a matter of due process, citing Lee’s limited education and potential intellectual disability, and the detective’s conduct during the interrogation.The Supreme Court of Georgia reviewed the State’s interlocutory appeal. It agreed with the lower court that Lee did not reinitiate communication after invoking his rights, and that the detective’s subsequent interrogation was improper under Miranda and Edwards. The court clarified that Lee’s follow-up questions were mere clarifying inquiries and not an indication of a desire to discuss the investigation. However, the Supreme Court of Georgia disagreed with the trial court’s finding that the statements were involuntary under due process principles, finding no evidence of coercive police activity. The court affirmed the suppression of Lee’s statements for the prosecution’s case-in-chief but reversed their exclusion for impeachment purposes if Lee testifies. View "STATE v. LEE" on Justia Law

Mark Isham and C.K. were in a long-term relationship, living together intermittently. In March 2023, after C.K. stayed with Isham following her release from a treatment center, the two drank alcohol and argued, resulting in Isham physically assaulting C.K. on two separate occasions. Several days after the second assault, C.K., who is an amputee, called 911 and reported being held against her will and physically abused. Police officers responded to Isham’s home, spoke separately to both individuals, and eventually arrested Isham after he admitted to hitting C.K. C.K. was hospitalized and required surgery for a fractured jaw.The United States District Court for the District of Minnesota heard Isham’s pretrial motions. The court denied Isham’s motion to suppress statements he made to officers before being arrested, concluding he was not in custody during the questioning. The court also partially granted a government motion to admit evidence of Isham’s prior assaults against C.K., allowing testimony about more recent incidents but excluding older ones. At trial, the jury acquitted Isham of assault with a dangerous weapon but convicted him of assault resulting in serious bodily injury and assault resulting in substantial bodily injury to an intimate partner.On appeal, the United States Court of Appeals for the Eighth Circuit reviewed the denial of the suppression motion de novo and found that Isham was not subjected to custodial interrogation before his arrest, as the questioning was brief, non-coercive, and Isham voluntarily participated. The appellate court also held that the district court did not abuse its discretion in admitting evidence of prior assaults, finding it relevant to issues raised at trial and adequately limited by jury instructions. The judgment of the district court was affirmed. View "United States v. Isham" on Justia Law

A member of the Lower Brule Sioux Tribe, the defendant moved onto the Swallow Ranch, located in the Cuny Table area of the Pine Ridge Indian Reservation, in 2022. He lived in a camper and worked as a ranch hand. During his time there, he developed a relationship with a 15-year-old girl, A.S., whom he taught to train horses and later groomed and sexually abused. The abuse occurred at various locations on and near the ranch, including a campground, a rock formation, and his camper. On one occasion, he also abused A.S.’s 12-year-old sister, N.S. The defendant further solicited nude photos from A.S. and from another minor, C.J.E., through Snapchat. When confronted by family members about the abuse, he denied the allegations and messaged N.S., urging her to claim A.S. was lying to protect himself from potential jail time. An FBI agent later investigated, uncovering evidence of the defendant’s communications and the sexual abuse.The United States District Court for the District of South Dakota tried the case. A jury convicted the defendant on multiple counts, including sexual abuse of a minor, abusive sexual contact, attempted sexual exploitation of a minor, attempted receipt of child pornography, and witness tampering. The district court denied the defendant’s motion for judgment of acquittal and sentenced him to 480 months in prison.Reviewing the appeal, the United States Court of Appeals for the Eighth Circuit affirmed the convictions for sexual abuse, abusive sexual contact, attempted sexual exploitation, and attempted receipt of child pornography, holding that sufficient evidence supported the jury’s findings. However, the court vacated the witness tampering conviction, finding insufficient evidence that the defendant contemplated a particular, foreseeable proceeding as required by law. The Eighth Circuit also vacated the entire sentence and remanded for resentencing in light of the vacated conviction. View "United States v. Goodlow" on Justia Law

The case involves a defendant who, along with others, participated in two separate home invasion robberies targeting the residence of Michael Robertson. Surveillance footage captured Williams and others attempting to break in one night, and returning the following night to forcibly enter, simulating a police raid. During the second invasion, gunshots were fired by others, resulting in the death of Jessica Brandon, though Williams was not armed at that time. Substantial quantities of drugs and cash were found in the home, suggesting the motive was robbery of a drug dealer.Williams was indicted in the United States District Court for the District of Nebraska on charges including murder with a firearm during a crime of violence and two counts of interference with commerce by robbery. He pleaded guilty and was initially sentenced to a total of 660 months’ imprisonment. After the Supreme Court decided in United States v. Taylor that Hobbs Act robbery does not qualify as a crime of violence under 18 U.S.C. § 924, Williams’s conviction for murder with a firearm was vacated by the United States Court of Appeals for the Eighth Circuit, which remanded the case for resentencing on the two remaining robbery counts.Upon resentencing, the district court imposed consecutive sentences of 222 months for each count, resulting in a total of 444 months. Williams appealed, arguing the district court erred in applying the sentencing package doctrine, failed to adequately explain the equal sentences for each count, and imposed an unreasonable sentence. The United States Court of Appeals for the Eighth Circuit held that application of the sentencing package doctrine was proper, the district court’s explanation was sufficient, and the sentence was not substantively unreasonable. The court affirmed the amended judgment. View "United States v. Williams" on Justia Law