Justia Criminal Law Opinion Summaries

Ms. Sokolosky pleaded guilty to two misdemeanors and received consecutive 11-month, 29-day sentences, which were suspended for supervised probation. In February 2020, an arrest warrant was issued for her alleged probation violations, including not reporting and not making scheduled payments. She was taken into custody in April 2022 and filed a motion to dismiss the warrant, arguing that the records were untrustworthy due to unethical practices by the private probation company. The trial court denied her motion, found her in violation of probation, and extended her supervision. She appealed the revocation order and the denial of her motion to dismiss.The Court of Criminal Appeals dismissed her appeal as moot, reasoning that since her sentence had expired and she was no longer in custody, there was no active controversy to resolve. The court found that the case no longer served as a means to provide judicial relief and distinguished it from State v. Rodgers, which involved the Juvenile Post-Commitment Act.The Supreme Court of Tennessee reviewed the case and disagreed with the Court of Criminal Appeals. The Supreme Court held that Ms. Sokolosky’s appeal was not moot because the probation violation could have adverse consequences even after the completion of her sentence, such as affecting future sentencing or bond decisions. The court cited State v. Rodgers, which held that probation violations could have subsequent adverse effects, thus maintaining a genuine and existing controversy. The Supreme Court reversed the decision of the Court of Criminal Appeals and remanded the case for consideration on the merits. View "State v. Sokolosky" on Justia Law

A man was indicted for first-degree sexual assault based on an incident that occurred in July 1999, in which the complaining witness testified that the defendant, whom she had known for less than two weeks and considered only a platonic friend, visited her home unannounced and forcibly raped her. The witness described her resistance and the emotional and psychological trauma she suffered afterward. DNA evidence collected at the time of the incident was later matched to the defendant. The prosecution also presented testimony from medical and forensic experts, as well as corroborating testimony from the witness’s friend, who received a distressed call from her shortly after the event.The case proceeded to a jury trial in the Providence County Superior Court in 2022, nearly twenty-three years after the alleged assault. The jury found the defendant guilty, and the trial justice denied his motion for a new trial. The defendant was sentenced to thirty-five years, with twelve years to serve and the remainder suspended with probation. The defendant appealed, arguing that the trial justice erred by refusing to instruct the jury on the defense of consent, by not giving a spoliation instruction regarding missing physical evidence (the jeans the witness wore), and by issuing an Allen charge to the deadlocked jury rather than declaring a mistrial.The Supreme Court of Rhode Island reviewed the case and affirmed the Superior Court’s judgment. The Court held that the trial justice’s instructions on force and coercion were adequate and that a separate consent instruction was unnecessary because there was no evidence of consent. The Court also found no error in refusing a spoliation instruction, as there was no evidence of bad faith or exculpatory value in the missing jeans. Finally, the Court concluded that the Allen charge given to the jury was fair, neutral, and not coercive under the circumstances. View "State v. Threadgill" on Justia Law

Three individuals, including the defendant, set out to purchase marijuana from a seller and his associate. En route, two of them decided to rob the seller instead. At the seller’s apartment, the defendant held several people at gunpoint while his accomplice searched for drugs. During a struggle, the defendant shot the seller in the face. The defendant denied involvement, claiming an alibi corroborated by his wife. Physical evidence, including DNA and video footage, as well as eyewitness testimony, linked the defendant to the scene. The defendant was convicted by a jury of first-degree murder, aggravated robbery, conspiracy, aggravated assault, and criminal possession of a firearm.The Johnson District Court presided over the trial, where the defendant raised several issues: prosecutorial error due to the prosecutor’s use of “we know” statements during closing argument, the prejudicial display of graphic photographs, limitations on witness questioning, acceptance of a stipulation regarding prior convictions without a jury trial waiver, and alleged speedy trial violations due to COVID-19 delays. The district court admitted the stipulation, allowed the display of photographs, and sustained objections to certain defense questions. The defendant was sentenced to a hard 25 years for felony murder plus additional consecutive and concurrent terms.The Supreme Court of the State of Kansas reviewed the case. It held that the prosecutor’s “we know” statements regarding contested facts constituted error, but found the errors harmless beyond a reasonable doubt given the strength of the evidence. The court ruled that the length of time admitted evidence is displayed is within the trial judge’s discretion and found no abuse of discretion here. It determined that the defense failed to preserve the issue regarding excluded witness testimony. The court found constitutional error in accepting the stipulation without a jury trial waiver but held it was harmless. COVID-19-related delays were weighed neutrally in the speedy trial analysis, and no violation was found. The convictions were affirmed. View "State v. Cherry " on Justia Law

Lynell Guyton was convicted by a jury of nine drug-trafficking, firearm, and money-laundering offenses. His criminal activities included ordering large quantities of fentanyl analogues from China, using Skype to communicate with suppliers, and making payments through MoneyGram. Law enforcement intercepted a package containing fentanyl analogues addressed to a pseudonym used by Guyton, leading to his arrest. Subsequent investigations revealed Guyton's continued involvement in drug trafficking and possession of firearms.The United States District Court for the Western District of Pennsylvania denied Guyton's motion for judgment of acquittal and sentenced him to 360 months' imprisonment on the primary drug charges, with concurrent sentences on the remaining counts. The court also applied recidivist enhancements based on Guyton's prior state conviction. Guyton appealed, raising several arguments, including instructional errors, constructive amendment of the indictment, and improper application of recidivist enhancements.The United States Court of Appeals for the Third Circuit reviewed the case. The court found that the District Court erred in denying Guyton's motion for judgment of acquittal on one of the firearm possession charges (Count 3) due to insufficient evidence of constructive possession. The court vacated this conviction and remanded for a judgment of acquittal on that count. However, the court affirmed the remaining convictions and sentences, finding no reversible error in the jury instructions, the alleged constructive amendment, or the application of recidivist enhancements. The court concluded that the instructional errors did not affect Guyton's substantial rights and that the evidence overwhelmingly supported the remaining convictions. View "United States v. Guyton" on Justia Law

B.J.S., a Native American born in 2004, was charged with multiple acts of aggravated sexual abuse against his younger sister L.S. between August 2019 and June 2022, when he was 15 to 17 years old. The government filed a juvenile information and moved to transfer the proceedings to adult court. The charges included causing L.S. to engage in sexual acts by force, engaging in sexual acts with L.S. under 12, and causing sexual contact with L.S. under 12 with intent to abuse, humiliate, harass, degrade, or arouse sexual desire.The United States District Court for the District of North Dakota granted the government's motion to transfer the case to adult court. B.J.S. moved to dismiss the transfer motion, arguing that the charges did not qualify as "crimes of violence" under 18 U.S.C. § 5032. The district court denied his motion and granted the transfer after an evidentiary hearing. B.J.S. appealed the decision.The United States Court of Appeals for the Eighth Circuit reviewed the case de novo. The court held that the charges under 18 U.S.C. §§ 2241(a), 2241(c), and 2244(a)(5) did not qualify as "crimes of violence" under 18 U.S.C. § 16(a). The court applied the categorical approach, considering only the statutory elements of the offenses. It found that § 2241(a) was overbroad and indivisible, covering more conduct than § 16(a). Similarly, § 2241(c) and § 2244(a)(5) did not require the use, attempted use, or threatened use of physical force against another person. Consequently, the court concluded that none of the charges met the definition of a "crime of violence" for purposes of § 5032 permissive transfer.The Eighth Circuit reversed the district court's decision and remanded the case, determining that the transfer to adult court was not justified. View "United States v. B.J.S." on Justia Law

Laguerre Payen, a federal inmate, was convicted in 2010 of multiple terrorism-related charges and sentenced to 25 years imprisonment. During his incarceration, Payen exhibited disruptive and dangerous behavior, including numerous assaults, threats, and other violations. He was diagnosed with schizophrenia and mild intellectual disability and was committed twice under 18 U.S.C. § 4245 for mental health treatment. Despite some improvement, Payen's behavior remained inconsistent, and he refused medication after his commitments ended.The United States District Court for the Western District of Missouri committed Payen under 18 U.S.C. § 4246, finding by clear and convincing evidence that his release would pose a substantial risk of bodily injury or serious property damage due to his mental illness. Payen appealed, arguing that the district court relied on erroneous facts and that the government failed to prove his dangerousness by clear and convincing evidence.The United States Court of Appeals for the Eighth Circuit reviewed the district court's finding of dangerousness for clear error. The court noted that the district court had relied on the unanimous opinions of experts, including an independent evaluator, who diagnosed Payen with schizophrenia and intellectual disability and concluded that his release would pose a substantial risk. The court also considered Payen's extensive history of violent and disruptive behavior, his refusal to take medication voluntarily, and the lack of a suitable release plan.The Eighth Circuit affirmed the district court's decision, finding no clear error in the determination that Payen's release would create a substantial risk of harm to others or their property. The court emphasized that the district court had properly focused on the expert reports and Payen's history of dangerous behavior in making its decision. View "United States v. Payen" on Justia Law

In 2020, Mujera Benjamin Lung’aho threw Molotov cocktails that damaged or destroyed three police cars belonging to state and municipal police departments. He was indicted under 18 U.S.C. § 844(f)(1) for maliciously destroying law enforcement vehicles possessed by local police departments receiving federal financial assistance. Lung’aho moved to dismiss the indictment, arguing that the statute was unconstitutional as applied to him.The United States District Court for the Eastern District of Arkansas denied Lung’aho’s motion to dismiss. The court held that while the Property Clause did not apply because the police cars were not federal property and were not bought with federal financial assistance, the prosecution was constitutional under the Spending Clause coupled with the Necessary and Proper Clause.The United States Court of Appeals for the Eighth Circuit reviewed the district court’s denial of the motion to dismiss de novo. The court held that Lung’aho’s conduct fell within the plain meaning of 18 U.S.C. § 844(f)(1) and that the statute was constitutional as applied to him. The court reasoned that under the Spending Clause and the Necessary and Proper Clause, Congress has the authority to ensure that federal funds are spent for the general welfare, and criminalizing the arson of police cars from departments receiving federal funding is a rational means of safeguarding federal dollars. The court affirmed the district court’s judgment, concluding that § 844(f)(1) was constitutionally applied to Lung’aho. View "United States v. Lung'aho" on Justia Law

The plaintiff, Julio Davila, was released on furlough in October 2021 following a 2014 conviction. In April 2022, he absconded from furlough, leading the Vermont Department of Corrections (DOC) to issue a "Return on Mittimus Request" and an arrest warrant. In August 2022, Davila was arrested in Massachusetts for driving with a suspended license and cocaine trafficking. He was held without bail on both the Vermont warrant and Massachusetts charges. In September 2022, Davila waived extradition to Vermont but remained incarcerated in Massachusetts until December 2023, when he was released on his own recognizance and transported to Vermont.Davila filed a grievance with the Vermont DOC, requesting credit towards his Vermont sentence for the time spent incarcerated in Massachusetts. The DOC denied his request, stating he was not under their supervision. Davila then filed a complaint in the Washington Civil Division, seeking a writ of mandamus to credit his Vermont sentence from September 2022 onwards. The court granted summary judgment to the DOC, concluding Davila was not entitled to credit for time served in Massachusetts.The Vermont Supreme Court reviewed the case de novo. The court held that under 28 V.S.A. § 808e(c), Davila was not entitled to sentence credit while a warrant was outstanding. The court also held that 13 V.S.A. § 7031(c) did not apply because Davila was not "awaiting transportation" to Vermont while incarcerated in Massachusetts. The court affirmed the lower court's decision, concluding Davila was not entitled to credit for the 490 days spent in Massachusetts. View "Davila v. Deml" on Justia Law

Joel Marvin Munt was convicted of first-degree premeditated murder and other related offenses in 2011 for the murder of his ex-wife, Svetlana Munt. He was sentenced to life in prison without the possibility of release. Munt filed his third petition for postconviction relief, arguing that the United States Supreme Court’s decision in Dobbs v. Jackson Women’s Health Organization rendered his conviction invalid on equal protection grounds. He also raised claims of entrapment, trial counsel’s disregard of his “defense objective of choice,” and witness tampering.The district court summarily denied Munt’s petition without a hearing. Munt appealed to the Minnesota Supreme Court. The court noted that Munt’s convictions became final in 2013 and that his current petition, filed in October 2023, was untimely under Minn. Stat. § 590.01, subd. 4(a)(2). The court also found that the Dobbs decision did not change the law as applied to Munt’s case, as his conviction for first-degree murder was unrelated to abortion laws.The Minnesota Supreme Court held that Munt’s claims were time-barred and that he did not establish a new interpretation of law that was retroactively applicable to his case. The court also concluded that Munt’s other claims, including witness tampering, trial counsel’s disregard of his “defense objective of choice,” and entrapment, were untimely and did not meet the interests-of-justice exception. The court affirmed the district court’s decision to deny Munt’s petition for postconviction relief. View "Munt v. State" on Justia Law

Almost 30 years after his conviction for first-degree murder was affirmed, Nantambu Noah Kambon filed a petition for postconviction relief, raising several issues and requesting a new trial. The district court denied the petition without an evidentiary hearing, citing its untimeliness. Kambon appealed, raising two issues from the district court and introducing a new argument on appeal.The district court found Kambon's petition untimely under Minnesota Statutes section 590.01, which requires postconviction petitions to be filed within two years after the judgment of conviction or the appellate court’s disposition on direct appeal. Since Kambon's conviction became final before August 1, 2005, the two-year limitation ended on August 1, 2007. The district court also rejected Kambon's argument that his claim qualified under the new interpretation of law exception, reasoning that the petition was filed nearly 30 years after his direct appeal concluded, and all issues raised were known or should have been known during previous petitions.The Minnesota Supreme Court reviewed the case and affirmed the district court's decision. The court held that Kambon's claims were untimely and did not qualify for any exceptions to the two-year time limitation. The court also rejected Kambon's new argument that the United States Supreme Court's decision in Loper Bright Enterprises v. Raimondo, which overruled Chevron U.S.A., Inc. v. Natural Resources Defense Council, Inc., applied to his case. The court clarified that the Chevron doctrine never applied to deference afforded to prior court decisions and that nothing in Chevron prevented Kambon from bringing his claims before 2007. Therefore, the court concluded that Loper Bright did not constitute a new interpretation of law that applied retroactively to Kambon's case. View "Kambon v. State" on Justia Law