Justia Criminal Law Opinion Summaries

In 2012, the appellant was charged with DUI and resolved the charge through acceptance into an Accelerated Rehabilitative Disposition (ARD) program. In 2020, he was again charged with DUI and convicted based on a guilty plea. The Pennsylvania Department of Transportation (PennDOT) received notice of his conviction and suspended his license for one year under Section 3804(e) of the Vehicle Code, which mandates a suspension for DUI convictions unless the individual has no prior offenses, including ARD acceptances within the past ten years.The appellant appealed the suspension to the Cumberland County Court of Common Pleas, which upheld the suspension despite the Superior Court's ruling in Commonwealth v. Chichkin, which disapproved of enhanced criminal sentencing based on an earlier ARD. The county court reasoned that the license suspension was a civil penalty and did not implicate the constitutional safeguards applicable in criminal matters. The Commonwealth Court affirmed this decision, agreeing that the suspension was a civil consequence and should be upheld as long as PennDOT acted in accordance with the law.The Supreme Court of Pennsylvania reviewed the case to determine whether the license suspension violated due process, given that the appellant's prior ARD acceptance was not a criminal conviction. The court held that the suspension did not violate due process. It reasoned that the suspension was based on the 2020 DUI conviction, not the prior ARD acceptance, and that the legislative scheme was rationally related to the state's interest in deterring drunk driving and ensuring public safety. The court affirmed the Commonwealth Court's order, upholding the one-year license suspension. View "Ferguson v. Dept. of Transportation" on Justia Law

Tyrese Harris was convicted of two counts of second-degree murder, one count of falsifying evidence, and one count of reckless conduct. The incident occurred on October 29, 2022, when Harris, driving with his fiancée, had a confrontation with the victim, a truck driver. After a traffic altercation, the victim approached Harris's vehicle aggressively, and Harris shot him in the head, resulting in the victim's death. Harris then fled the scene, drove erratically, and later hid at a friend's apartment. The police did not recover the firearm used in the shooting.The Superior Court admitted a recorded phone call between Harris and his mother, where Harris discussed the incident, and instructed the jury on the reasonable necessity of Harris's use of deadly force. Harris's motion to dismiss the falsifying evidence charge for insufficient evidence was denied. The jury convicted Harris on all charges.The Supreme Court of New Hampshire reviewed the case. The court upheld the trial court's decision to admit the recorded phone call, finding it highly probative of Harris's state of mind and not unfairly prejudicial. The court also upheld the jury instruction on the reasonable necessity of using deadly force, aligning with the common law requirement that such force must be reasonably necessary.However, the court found insufficient evidence to support the conviction for falsifying physical evidence. The State's circumstantial evidence did not exclude all reasonable conclusions other than Harris's guilt, as the firearm was never recovered, and there was no direct evidence that Harris concealed or destroyed it. Consequently, the court reversed the conviction for falsifying evidence but affirmed the other convictions. View "State v. Harris" on Justia Law

A prisoner was observed by a corrections officer receiving a crumpled piece of paper from another inmate. The officer demanded the prisoner hand over the paper, which contained two orange strips later identified as Suboxone, a controlled substance. The prisoner did not have a prescription for Suboxone. Initially, the prisoner tested positive for Suboxone, but a retest was negative. The prisoner was charged with being a prisoner in possession of a controlled substance (PPCS).The 85th District Court bound the prisoner over for trial, concluding there was sufficient evidence for probable cause without ruling on whether PPCS required a mens rea element. The Manistee Circuit Court denied the prisoner's motion to include a mens rea element in the jury instructions, relying on a previous case, People v Ramsdell, which held PPCS to be a strict-liability offense. The Court of Appeals affirmed the conviction, agreeing that PPCS is a strict-liability crime.The Michigan Supreme Court reviewed the case to determine if PPCS is a strict-liability offense or if it requires a mens rea element. The Court held that MCL 800.281(4) does not plainly impose strict liability and that MCL 8.9(3) applies, requiring the prosecution to prove that the defendant acted with intent, knowledge, or recklessness. The Court reversed the Court of Appeals' decision and remanded the case to the trial court for further proceedings consistent with this opinion. View "People v. Tadgerson" on Justia Law

In 2014, Michael Andrew Cota was charged with four counts of sexual abuse, including committing a lewd act upon a child under 14. The complaint also included allegations of a prior strike conviction, a prior serious felony conviction, a prior prison term for a violent felony, and three prior prison terms under Penal Code section 667.5, subdivision (b). In 2015, Cota entered a plea agreement, pleading guilty to the lewd act charge and admitting the prior convictions and prison terms. In return, other charges were dismissed, and he was sentenced to 24 years in prison, with the punishment for two of the prison priors being struck.The California Department of Corrections and Rehabilitation (CDCR) identified Cota as eligible for resentencing under section 1172.75, which invalidates certain prison priors. However, the trial court denied resentencing in August 2022, reasoning that Cota was not eligible because the punishment for the prison priors was struck. Cota appealed this decision, arguing that the trial court erred in its interpretation of section 1172.75.The California Court of Appeal, Sixth Appellate District, reviewed the case. The court concluded that the trial court had jurisdiction to resentence Cota despite CDCR's delayed notification. The court determined that CDCR's notification obligation is directory, not mandatory or jurisdictional. The court also held that section 1172.75 requires resentencing even if the punishment for prison priors was struck, following the precedent set by People v. Espino. Consequently, the court reversed the trial court's decision and remanded the case for a full resentencing consistent with section 1172.75 and current law. View "People v. Cota" on Justia Law

In this case, the defendant was convicted of kidnapping resulting in death under 18 U.S.C. § 1201(a)(1). The incident occurred in February 2019, when the defendant encountered the victim in downtown Boston, Massachusetts. They walked to his car together, and he later drove to his apartment in Providence, Rhode Island. Surveillance footage showed him carrying the victim's limp body into his apartment. Four days later, police found the victim's dead body in the defendant's car trunk in Delaware. The defendant was arrested and charged with kidnapping resulting in death.The United States District Court for the District of Massachusetts conducted the trial, where the jury found the defendant guilty. The court sentenced him to life in prison without the possibility of parole. The defendant appealed, alleging various errors in the district court proceedings, including issues with the indictment, denial of a bill of particulars, and the admission and exclusion of certain evidence.The United States Court of Appeals for the First Circuit reviewed the case. The court found no error in the district court's proceedings. It held that the indictment was sufficient, the denial of a bill of particulars was not an abuse of discretion, and the evidence admitted and excluded was handled appropriately. The court also found that the jury instructions were proper and that there was sufficient evidence to support the conviction. The court affirmed the defendant's conviction and sentence. View "United States v. Coleman" on Justia Law

Frederick Brewer was convicted by a jury of distributing fentanyl, possessing with intent to distribute fentanyl, and participating in a conspiracy to distribute fentanyl. The jury, however, found that the government did not prove beyond a reasonable doubt that Brewer's conspiracy and possession convictions involved at least 40 grams of fentanyl. Brewer moved for acquittal twice, arguing insufficient evidence, but the district court denied both motions. Brewer appealed, contending that the evidence was insufficient to support his convictions and that the district court erred in calculating the drug quantity for sentencing.The United States District Court for the Eastern District of Wisconsin initially denied Brewer's motions for acquittal. The court found sufficient evidence to establish that Brewer and his co-defendant, Don James, Jr., were engaged in a conspiracy to distribute fentanyl, rather than a simple buyer-seller relationship. The court also rejected Brewer's argument that the jury's finding regarding the drug quantity undermined the guilty verdicts. At sentencing, the district court attributed 1.2 to 4 kilograms of fentanyl to Brewer, resulting in a higher base offense level and a sentence of 144 months in prison followed by 120 months of supervised release.The United States Court of Appeals for the Seventh Circuit reviewed the case and affirmed the district court's decisions. The appellate court held that the evidence was sufficient to support Brewer's convictions for conspiracy, possession, and distribution of fentanyl. The court also upheld the district court's drug quantity determination for sentencing purposes, noting that the sentencing court could consider conduct underlying acquitted charges if proven by a preponderance of the evidence. Brewer's conviction and sentence were affirmed. View "United States v. Brewer" on Justia Law

The defendant was convicted of three first-degree murders and several related offenses, including rape and sexual penetration with a foreign object, committed between 1988 and 1998 in Stockton and Oakland, California. The prosecution’s case relied heavily on DNA evidence linking the defendant to the victims, as well as ballistics evidence connecting the same firearm to multiple murders. The victims were found in isolated areas, often bound, and killed by gunshots to the head. The defendant was also convicted of the rape and kidnapping of another woman, Yvette R., who survived and testified. The defense presented no evidence at the guilt phase but, during the penalty phase, offered expert testimony about the defendant’s abusive childhood and mental health issues, including sexual sadism.The San Joaquin County Superior Court jury found the defendant guilty on all counts, found true the special circumstance allegations (multiple murders and murder during rape), and returned death verdicts for each murder. The court imposed a death sentence and additional terms for the noncapital offenses. The defendant’s appeal to the Supreme Court of California was automatic.The Supreme Court of California reviewed numerous claims, including alleged instructional errors, challenges to the constitutionality of special circumstances, claims of prosecutorial misconduct, and issues related to victim impact evidence and penalty phase instructions. The court held that there was no substantial evidence to support instructions on voluntary manslaughter or that the victims were dead at the time of sexual assault, and found no reversible error in the instructions given. The court also rejected challenges to the constitutionality of California’s death penalty scheme and the admission of victim impact evidence. The court found harmless any error in failing to redefine reasonable doubt at the penalty phase and in the response to a jury question about parole eligibility. The judgment was affirmed in its entirety, with a minor correction to the firearm enhancement terms. View "People v. Choyce" on Justia Law

Donnie Bryant, a member of a Las Vegas-based street gang, participated in a gang-related shooting at the age of sixteen, resulting in a 70-year prison sentence. He was convicted under the Violent Crimes in Aid of Racketeering (VICAR) statute and for using a firearm during a crime of violence. Decades later, Bryant sought compassionate release, arguing that his youth at the time of the offense, a sentencing disparity with his codefendant, and the alleged improper "stacking" of his firearm sentences under the First Step Act constituted "extraordinary and compelling" reasons for relief.The United States District Court for the District of Nevada denied Bryant's motion. The court held that while youth could be considered in an appropriate case, Bryant's crime was not the product of youthful immaturity, and he had not demonstrated significant rehabilitation. The court also found that the sentencing disparity with his codefendant, who received a reduced sentence through a plea deal, was not an extraordinary and compelling reason for release. Additionally, the court rejected Bryant's argument regarding the stacking of his firearm sentences, noting that his sentences were imposed correctly under the law at the time.The United States Court of Appeals for the Ninth Circuit affirmed the district court's decision. The appellate court held that a defendant's youth at the time of the offense is not an extraordinary and compelling reason for compassionate release under the Sentencing Guidelines. The court also ruled that a sentencing disparity resulting from a codefendant's guilty plea does not qualify as an extraordinary and compelling reason. Lastly, the court clarified that Bryant's sentences for his firearm convictions were not improperly stacked in violation of the First Step Act, as the Act's amendments did not apply to his case. View "United States v. Bryant" on Justia Law

Raul Perez Cruz, a native and citizen of Mexico, pled guilty to money laundering in 2021 and was sentenced to 144 months in prison. The Department of Homeland Security initiated removal proceedings against him. He conceded removability but sought asylum, withholding of removal, and protection under the Convention Against Torture (CAT) based on past experiences with cartels and fear of retaliation due to his purported cooperation with the U.S. government.An Immigration Judge (IJ) denied his applications for asylum and withholding of removal due to his conviction of a particularly serious crime. The IJ also denied his CAT claim, finding that he did not show it was more likely than not he would be tortured upon return to Mexico, nor that he could not safely relocate within Mexico. The Board of Immigration Appeals (BIA) affirmed the IJ’s decision, agreeing that his fear of future torture was speculative and that there was no due process violation despite technical difficulties during the hearing.The United States Court of Appeals for the Ninth Circuit reviewed the case. The court held that substantial evidence supported the agency’s determination that Perez Cruz did not meet his burden to show he would more likely than not be tortured if returned to Mexico. The court also found that Perez Cruz did not overcome the presumption that the agency reviewed all evidence before it. Additionally, the court was not persuaded by his contention that audio issues during his hearing denied him due process, as there was no demonstration that the IJ prejudicially missed or misunderstood anything said during the hearing. The petition for review was denied. View "Perez Cruz v. Bondi" on Justia Law

Miguel Alcantar Mercado participated in a drug distribution operation, possessing and distributing over 1,300 grams of heroin and wiring more than $45,000 in drug proceeds. He pled guilty to conspiracy to distribute a controlled substance. The United States Probation Office calculated an advisory Guidelines range of 210 to 262 months’ imprisonment, factoring in his criminal history. The district court sentenced him to 204 months, six months below the Guidelines range, considering both the seriousness of the offense and mitigating factors such as his modest criminal history and family support.Following a retroactive amendment to the Sentencing Guidelines, which revised the calculation of criminal history categories, Alcantar Mercado’s criminal history category was reduced from III to II, making his new Guidelines range 188 to 235 months. This made him eligible for a discretionary sentence reduction. The Probation Office identified him as eligible, noting his good behavior and participation in rehabilitative programs. However, the district court declined to modify his sentence, stating that the variance he received was consistent with the new Guidelines range.The United States Court of Appeals for the Eighth Circuit reviewed the district court’s decision for abuse of discretion. The court found that the district court had considered the relevant factors under 18 U.S.C. § 3553(a) and noted Alcantar Mercado’s good behavior. The appellate court held that the district court was not required to provide a lengthy explanation for its decision and that its consideration of the factors was sufficient. The Eighth Circuit affirmed the district court’s judgment, concluding that the decision was within the permissible range of discretion. View "United States v. Mercado" on Justia Law