Justia Criminal Law Opinion Summaries

A 93-year-old woman was found dead in her Stamford, Connecticut home in September 2019, having suffered multiple blunt force injuries. The back door was found open, her wallet was empty and bloodstained, her wedding rings were missing, and a hammer believed to be the murder weapon was found nearby. Video surveillance from a neighboring business showed only one person, later identified as the defendant, entering and exiting the victim’s home during the relevant time. Forensic evidence included the victim’s blood on the defendant’s jeans and the defendant’s DNA on the victim’s fingernails. The defendant initially denied knowing the victim or being in the area, but later admitted to visiting her home that day, claiming it was a brief, uneventful visit.The defendant was charged in the Superior Court for the judicial district of Stamford-Norwalk with murder, home invasion, felony murder, and burglary in the first degree. A jury convicted him on all counts, but the trial court vacated the felony murder conviction on double jeopardy grounds and rendered judgment on the remaining charges, sentencing him to eighty-five years in prison. The defendant appealed, arguing insufficient evidence, improper denial of a third-party culpability jury instruction, and prosecutorial impropriety during closing arguments.The Connecticut Supreme Court affirmed the conviction. It held that the evidence, including surveillance footage, forensic results, and the defendant’s contradictory statements, was sufficient for the jury to find guilt beyond a reasonable doubt. The court found no abuse of discretion in the trial court’s refusal to instruct the jury on third-party culpability, as the presence of unknown male DNA on the hammer did not, in context, provide a credible alternative theory of guilt. The court also concluded that the prosecutor’s remarks during argument were not improper and did not deprive the defendant of a fair trial. View "State v. Simmons" on Justia Law

The defendant was convicted of multiple crimes, including first-degree robbery, following an armed robbery at a restaurant. The police apprehended the defendant shortly after the robbery and conducted a one-on-one showup identification with a restaurant employee, Brinkley, who identified the defendant as one of the perpetrators. The defendant moved to suppress this identification, arguing it was unnecessarily suggestive and unreliable. The trial court denied the motion, finding the identification procedure was not unduly suggestive and, even if it was, the identification was reliable under the totality of the circumstances.The Appellate Court affirmed the trial court's decision, concluding that the showup identification was not unnecessarily suggestive due to the exigent circumstances of the investigation. The court noted that the police needed to quickly determine if they had apprehended the correct suspect to continue their investigation effectively and ensure public safety.The Supreme Court of Connecticut reviewed the case, assuming arguendo that the showup procedure was unnecessarily suggestive. The court focused on the reliability of the identification, considering factors such as Brinkley's opportunity to view the defendant during the crime, her degree of attention, the accuracy of her prior description, her level of certainty during the identification, and the short time between the crime and the identification. The court found substantial evidence supporting the trial court's finding of reliability, noting that Brinkley provided a detailed and accurate description of the perpetrators, identified the defendant without hesitation, and the identification occurred shortly after the crime.The court also addressed the defendant's arguments regarding estimator variables, such as the potential impact of Brinkley's fear, possible marijuana use, and the presence of a weapon. The court concluded that these factors did not undermine the reliability of the identification. Consequently, the Supreme Court of Connecticut affirmed the Appellate Court's judgment, holding that the identification was reliable and did not violate the defendant's due process rights. View "State v. McLaurin" on Justia Law

The defendant was convicted of murder and criminal possession of a firearm in connection with the shooting death of the victim. After the jury foreperson announced a guilty verdict and the jurors collectively confirmed it, defense counsel requested individual polling of the jurors. The first five jurors confirmed the verdict, but the sixth juror, S.C., expressed uncertainty and disagreement. The court stopped polling and excused the jurors to consult with counsel. The court then directed the jurors to resume deliberations, and they later returned a unanimous guilty verdict.In the trial court, the defendant moved for a mistrial, arguing that S.C. would face undue pressure in deliberations. The court denied the motion, noting that S.C. had expressed second thoughts and wanted to continue deliberating. The jury deliberated for an additional two hours after a lunch break and returned a unanimous guilty verdict, which was confirmed by all jurors during a second poll.The Supreme Court of Connecticut reviewed the case and held that the trial court did not abuse its discretion in denying the motion for a mistrial. The court found no impermissible coercion of S.C., noting that the trial court's actions were neutral and allowed the deliberation process to continue without undue pressure. The court also concluded that the trial court's instructions to the jury were adequate and did not require a Chip Smith charge. The court affirmed the judgment of conviction, rejecting the defendant's claims of coercion and procedural error. View "State v. Bolton" on Justia Law

In 2017, Darrell Wickware was convicted of robbery under Texas law and sentenced to three years in prison. In May 2021, he was found with a 9-millimeter pistol and charged with unlawful possession of a firearm by a convicted felon. In January 2022, he was indicted for violations of 18 U.S.C. §§ 922(g)(1) and 924(a)(2) and pleaded guilty. At his sentencing hearing in June 2024, Wickware argued that his prior robbery conviction did not qualify as a "crime of violence" under the amended Sentencing Guidelines. The district court, bound by Fifth Circuit precedent, sentenced him to 24 months in prison. Wickware appealed.The United States District Court for the Northern District of Texas ruled that Wickware's robbery conviction was a crime of violence under the Sentencing Guidelines. Wickware appealed, arguing that amendments to the Guidelines changed the characterization of his robbery conviction. The district court disagreed, stating it was bound by Fifth Circuit precedent, and sentenced Wickware to 24 months in prison.The United States Court of Appeals for the Fifth Circuit reviewed the case. Wickware contended that the district court erred in finding his argument foreclosed by circuit precedent. The Fifth Circuit examined the elements of Texas robbery and the amended Guidelines' definition of robbery. The court found that the elements of Texas robbery were the same or narrower than those of the Guidelines' generic robbery offense. Consequently, the court held that Wickware's Texas robbery conviction constituted a "crime of violence" under U.S.S.G. § 4B1.2(a)(2). The Fifth Circuit affirmed the district court's decision. View "United States v. Wickware" on Justia Law

Erik Willis was convicted of attempted murder for the unprovoked stabbing of a woman sunbathing on a beach. The main issue at trial was the identification of Willis as the assailant. Surveillance footage and witness testimonies placed Willis near the scene, and the victim identified him as her attacker. Willis appealed, arguing that the Deputy Prosecuting Attorney (DPA) committed prosecutorial misconduct by misstating evidence during closing arguments.The Intermediate Court of Appeals (ICA) vacated Willis’s conviction, agreeing that the DPA’s statements constituted prosecutorial misconduct. The ICA found that the DPA introduced new evidence of blood on Willis’s hands and shirt, which was not supported by the trial record, and concluded that there was a reasonable possibility that these statements contributed to Willis’s conviction.The State of Hawai‘i petitioned the Supreme Court of Hawai‘i to reverse the ICA’s decision. The State argued that the DPA’s statements were based on reasonable inferences from the evidence presented and, even if improper, were harmless beyond a reasonable doubt.The Supreme Court of Hawai‘i agreed with the State, holding that the DPA’s remarks did not rise to the level of prosecutorial misconduct. The court found that the DPA’s comments were based on reasonable inferences from the evidence and that there was no reasonable possibility that these comments alone affected the trial’s outcome. Consequently, the Supreme Court vacated the ICA’s judgment and affirmed the Circuit Court of the First Circuit’s amended judgment of conviction and sentence for attempted murder in the second degree. View "State v. Willis" on Justia Law

Christopher Scott was charged with first-degree robbery, armed criminal action, and unlawful use of a weapon. After a jury trial, he was found guilty on all counts and sentenced in November 2020. The Missouri Court of Appeals affirmed his conviction, and the mandate was issued on January 19, 2022. Scott then filed a pro se Rule 29.15 motion for postconviction relief on April 11, 2022, raising three claims. A public defender entered an appearance on his behalf but did not request an extension to file an amended motion. The public defender filed an amended motion on August 4, 2022, raising six claims, including the original three. The motion court denied relief on all claims after an evidentiary hearing.The Missouri Court of Appeals reviewed the case and transferred it to the Supreme Court of Missouri. The Supreme Court of Missouri noted that the amended motion was filed late and without an extension request. The court emphasized that the deadlines in Rule 29.15 are mandatory and that the abandonment doctrine, which can excuse untimely filings, applies only to appointed counsel, not to unappointed counsel. Since the public defender was not officially appointed, the abandonment doctrine did not apply.The Supreme Court of Missouri held that the motion court should not have considered the untimely claims in the amended motion. As Scott did not challenge the denial of his original pro se claims, the court affirmed the motion court's judgment denying postconviction relief on those claims. The court concluded that the amended motion's additional claims were not properly before the motion court due to the untimely filing. Therefore, the judgment of the motion court was affirmed. View "Scott v. State" on Justia Law

Cedric Mack was charged with driving while intoxicated as a persistent offender. After a jury trial, he was found guilty and sentenced by the circuit court. Mack appealed, and the court of appeals affirmed his conviction. Subsequently, Mack filed a pro se Rule 29.15 motion for postconviction relief, which included a request for a public defender. A public defender later entered an appearance and filed an amended motion. The motion court overruled the amended motion after an evidentiary hearing. Mack appealed, and the court of appeals remanded the case for findings of fact, conclusions of law, and an abandonment inquiry. On remand, the motion court found the public defender had abandoned Mack, considered the amended motion on the merits, and denied relief again. Mack appealed.The Supreme Court of Missouri reviewed the case. The court noted that Mack's amended motion was not timely filed under the applicable version of Rule 29.15(g). The court also found that the public defender's entry of appearance without being appointed meant the abandonment doctrine did not apply. Consequently, the only issue was whether Mack's single pro se claim needed to be resolved again. The court determined it did not, as the claim had already been raised and decided in Mack's direct appeal.The Supreme Court of Missouri held that Mack's pro se Rule 29.15 motion was the only timely filed motion and contained a single claim identical to one previously rejected on direct appeal. Therefore, the judgment of the motion court denying postconviction relief was affirmed. View "Mack v. State" on Justia Law

In 2020, C.S. pleaded guilty to two charges in the Lafayette County circuit court: possession of a controlled substance for possessing more than 35 grams of marijuana, and unlawful use of a weapon for possessing a firearm while knowingly in possession of a controlled substance. He was sentenced to seven years and four years of imprisonment, respectively, but the execution of his sentence was suspended. After his probation was revoked in 2021, C.S. was incarcerated. Following the approval of Amendment 3 in 2022, which allows expungement for certain marijuana offenses, C.S. filed a petition to expunge both convictions.The Lafayette County circuit court expunged C.S.'s conviction for possession of a controlled substance but denied the petition to expunge the conviction for unlawful use of a weapon. The court reasoned that the unlawful use of a weapon is a "weapons offense" and not eligible for expungement under the Missouri Constitution's article XIV, § 2.10(7)(a)c.The Supreme Court of Missouri reviewed the case and affirmed the circuit court's judgment. The court held that the offense of unlawful use of a weapon for possessing a firearm while knowingly in possession of a controlled substance is not a "marijuana offense" within the meaning of article XIV, § 2 of the Missouri Constitution. The court concluded that the primary purpose of the statute criminalizing unlawful use of a weapon is to prevent conduct that endangers others, and therefore, it is not eligible for expungement under the constitutional provision. View "C.S. v. Missouri State Highway Patrol Criminal Justice Information Service" on Justia Law

In August 2018, Jessie Nelson was seen at the scene of a shooting that resulted in one death and one permanent injury. He was charged with first-degree murder, first-degree assault, and two counts of armed criminal action. After a jury trial, Nelson was found guilty on all counts and sentenced in January 2020. The court of appeals affirmed the conviction in December 2021. Nelson filed a pro se Rule 29.15 motion in March 2022, and a public defender was appointed the same day. The public defender filed an amended motion in July 2022, which was overruled after an evidentiary hearing in August 2023. Nelson appealed.Cameron Woods was charged with unlawful use of a weapon and entered an open plea of guilt in March 2021. He was sentenced to 15 years’ imprisonment in May 2021. Woods did not appeal but filed a pro se motion under Rule 24.035 in October 2021. A public defender was appointed in November 2021, and an amended motion was filed in April 2022. The motion was overruled after an evidentiary hearing in November 2023. Woods appealed.The Supreme Court of Missouri reviewed the cases and found that both Nelson and Woods were abandoned by their appointed counsel due to untimely filing of amended motions. The court determined that remand for an abandonment inquiry was unnecessary as the records clearly showed abandonment. The court affirmed the motion courts' judgments, finding no clear error in their rulings on the merits after conducting evidentiary hearings. Nelson's claims of ineffective assistance of counsel were denied, and Woods' claim regarding the failure to call an expert witness at sentencing was also denied. The judgments denying postconviction relief were affirmed. View "Nelson v. State" on Justia Law

Donald Booker owned and operated United Youth Care Services, which billed North Carolina’s Medicaid program for millions of dollars’ worth of medically unnecessary drug tests. Booker was involved in a scheme where his company, along with United Diagnostic Laboratories, recruited individuals to submit to drug testing, which was then billed to Medicaid. The company used several medical providers to certify the testing as medically necessary, even though these providers often did not meet with the beneficiaries. Booker directed the testing protocols, which included testing all participants twice per week regardless of medical need. He also arranged kickback schemes with other entities to recruit Medicaid beneficiaries for the drug tests.The United States District Court for the Western District of North Carolina convicted Booker on ten counts, including conspiracy to defraud the United States, commit health care fraud, pay illegal kickbacks, and money laundering. Booker represented himself at trial, and the jury found him guilty on all counts. The district court denied his motion for judgment of acquittal and sentenced him to 200 months in prison, considering a loss amount exceeding $9.5 million.The United States Court of Appeals for the Fourth Circuit reviewed the case and affirmed the district court’s judgment. The appellate court found that there was substantial evidence to support Booker’s convictions, including testimony from co-conspirators and evidence of kickback payments. The court also rejected Booker’s arguments regarding the nondelegation doctrine, the sufficiency of the evidence for his money-laundering convictions, and the alleged Confrontation Clause violations. The court upheld the district court’s loss-amount calculation and found Booker’s sentence to be substantively reasonable, noting that his co-defendants were not similarly situated and had cooperated with the government. View "United States v. Booker" on Justia Law