Justia Criminal Law Opinion Summaries

Federal agents conducted a sting operation in which Rami Ghanem attempted to export military equipment from the United States to Libya. Ghanem pleaded guilty to six counts, including violations of the Arms Export Control Act, unlawful smuggling, and money laundering. He proceeded to trial on a charge of conspiring to acquire, transport, and use surface-to-air missiles, for which he was found guilty and initially sentenced to 360 months in prison.The United States Court of Appeals for the Ninth Circuit vacated Ghanem’s conviction on the missile conspiracy charge due to improper jury instructions on venue and remanded the case for resentencing. On remand, the district court recalculated the guidelines range as 78-97 months but imposed the same 360-month sentence, considering the same relevant conduct as before.The Ninth Circuit reviewed Ghanem’s appeal, rejecting his arguments that the district court committed procedural errors at resentencing. The court held that the district court applied the correct legal standards in declining to reduce Ghanem’s offense level for acceptance of responsibility and did not clearly err in finding that Ghanem’s failure to accept responsibility outweighed his guilty plea and truthful admissions. The court also found that the district court adequately explained its sentencing decision, addressed Ghanem’s argument about sentencing disparities, and correctly considered conduct underlying the dismissed charge.The Ninth Circuit affirmed the 360-month sentence, concluding that the district court did not abuse its discretion in determining that the sentence was warranted under the 18 U.S.C. § 3553(a) factors. The court also rejected Ghanem’s constitutional arguments under Apprendi v. New Jersey, holding that the district court’s reliance on conduct underlying the dismissed charge did not violate the Fifth or Sixth Amendments. View "United States v. Ghanem" on Justia Law

A police officer stopped a vehicle driven by the defendant after learning that the vehicle’s registered owner had a suspended license, but before identifying the driver. The defendant moved to suppress the evidence from the stop, arguing that the officer lacked reasonable suspicion because the driver was not identified before the stop. The trial court denied the motion, concluding it was reasonable for the officer to infer that the registered owner was driving. The defendant was convicted of driving with a suspended license.On appeal, the defendant acknowledged that the stop would be lawful under the Court of Appeals case law, State v. Panko, but argued that Panko was wrongly decided and should be overruled. The Court of Appeals disagreed, concluding that Panko was not "plainly wrong" and was binding. The defendant then sought review from the Oregon Supreme Court.The Oregon Supreme Court affirmed the decision of the Court of Appeals. The court held that an officer has reasonable suspicion to make an investigatory stop when the officer believes, based on specific articulable facts, that the person stopped has committed or is about to commit a specific crime, and that belief is objectively reasonable under the circumstances. The court concluded that the officer’s suspicion that the defendant was driving with a suspended license was objectively reasonable because the officer saw a vehicle matching the description and license plate of the defendant’s vehicle, knew the defendant’s license was suspended, and confirmed the defendant was the sole registered owner. The court held that these facts made the officer’s inference objectively reasonable, and the possibility that someone else was driving did not undercut this reasonableness. The decision of the Court of Appeals and the judgment of the circuit court were affirmed. View "State v. Betancourt" on Justia Law

Deoman Reeves was convicted by a jury of eleven counts related to narcotics and firearms offenses. The charges stemmed from a series of events in 2019, including a shooting incident in University City, Missouri, and subsequent involvement in drug and firearms trafficking. Reeves was identified as a primary suspect in the shooting and was linked to a narcotics trafficking organization. He was involved in a retaliatory shooting that resulted in the death of a bystander, David Anderson, whom Reeves mistakenly believed to be a rival drug trafficker. Reeves was later involved in several controlled buys of fentanyl and firearms set up by ATF agents.The United States District Court for the Eastern District of Missouri denied several of Reeves's pretrial motions, including a motion to suppress location data obtained from his cellphones and a motion to sever the count charging him with possession of a firearm in furtherance of a drug trafficking crime resulting in death. The district court also denied Reeves's motions for judgment of acquittal and for a new trial. Reeves was sentenced to life imprisonment on one count, 120 months on seven counts to be served concurrently, and 60 months on three counts to be served consecutively.The United States Court of Appeals for the Eighth Circuit reviewed the case and found no reversible error. The court held that the district court did not abuse its discretion or plainly err in denying the motion to sever, as the offenses were connected to the same drug trafficking conspiracy. The court also upheld the denial of the motion to suppress, finding that the warrants were supported by probable cause and sufficiently particular. The court affirmed the denial of the motion for judgment of acquittal, concluding that sufficient evidence supported the convictions. Finally, the court determined that Reeves waived his challenges to the jury instructions by not objecting during the trial. The judgment of the district court was affirmed. View "United States v. Reeves" on Justia Law

Logan Gregory Gosselin pled guilty to one count of sexual exploitation of a child and was sentenced to three to eight years in prison, with a recommendation for the Youthful Offender Transition Program (YOTP). Nearing completion of the YOTP, Gosselin filed a motion for sentence reduction, which the district court denied. Gosselin appealed, arguing that the district court abused its discretion and violated his constitutional rights by not honoring an earlier promise to reduce his sentence upon successful completion of the YOTP.The district court of Laramie County initially sentenced Gosselin and included a written judgment suggesting an expectation of sentence reduction if he completed the YOTP. However, the judge who issued the original sentence retired, and a new judge denied Gosselin's motion for sentence reduction without a hearing. Gosselin's appeal contended that the denial was an abuse of discretion and violated his due process and double jeopardy rights.The Wyoming Supreme Court reviewed the case and found that the district court did not abuse its discretion. The court clarified that the written judgment's language about an "expectation" of sentence reduction did not constitute a binding promise. The court also determined that the district court's oral pronouncement did not guarantee a sentence reduction but merely indicated that Gosselin would likely return to court to request it. The Supreme Court held that the district court's denial of the motion did not violate Gosselin's due process rights, as there was no protected interest in a guaranteed sentence reduction. Additionally, the court found no double jeopardy violation, as the denial of the motion did not increase Gosselin's original sentence. The Wyoming Supreme Court affirmed the district court's decision. View "Gosselin v. State" on Justia Law

Michael Isreal Robin, Sr. was convicted by a jury on multiple counts, including theft of a vehicle, possession of cocaine, property destruction, possession of methamphetamine, and possession of marijuana. The appeal focuses solely on the conviction for theft of a vehicle. Robin contends that the State of Wyoming presented insufficient evidence to prove he exercised control over the vehicle without the owner's authorization.The District Court of Laramie County held a two-day jury trial in November 2024. The State called two witnesses: the investigating officer and the vehicle's owner, Gloria Landeroz. Officer Maljian testified about the surveillance and subsequent high-speed chase that led to Robin's arrest. Landeroz testified that she had loaned the vehicle to Robin but expected it to be returned before the day of the crash. She was uncertain about the exact dates but clarified that Robin did not have permission to use the vehicle on the day of the incident. Robin's motion for a judgment of acquittal was denied by the district court, and the jury found him guilty of vehicle theft.The Supreme Court of Wyoming reviewed the case, focusing on whether the State presented sufficient evidence to support the conviction. The court noted that the standard of review requires assuming the State's evidence is true and giving the State the benefit of every favorable inference. The court found that Landeroz's testimony, despite her memory issues, provided sufficient evidence for the jury to conclude that Robin did not have authorization to use the vehicle at the time of the incident. The court affirmed the conviction, holding that a reasonable jury could have found Robin guilty beyond a reasonable doubt based on the evidence presented. View "Robin v. State" on Justia Law

A detective from the Cheyenne Police Department investigated a break-in and vehicle theft at Swagger Construction on October 10, 2023. The project manager reported missing items, including a company truck and flatbed trailer, and noted "Claim Ins" written on a calendar. The security footage was also missing. The detective later found the stolen trailer on someone's property, loaded with tools, equipment, and a Jeep registered to Andrew Michael Hanson. Hanson was arrested for leaving the scene of an accident while driving the stolen truck. The detective found the missing security footage in the truck, which showed Hanson entering the building through a window and taking items.The State charged Hanson with burglary and felony theft. At trial, the State presented testimony from the arresting officer, the project manager, and the detective, and introduced the security footage as evidence. Hanson moved for a judgment of acquittal, arguing insufficient evidence that he acted without authority. The district court denied the motion, and the jury found Hanson guilty on both counts. He was sentenced to two to four years of incarceration, suspended in favor of three years of probation.The Wyoming Supreme Court reviewed the case, focusing on whether the State presented sufficient evidence for the jury to conclude beyond a reasonable doubt that Hanson acted without authority. The court held that the State provided strong circumstantial evidence, including the project manager's testimony, the security footage, and the detective's findings. The court affirmed Hanson's convictions, concluding that the evidence was sufficient for the jury to reasonably infer that Hanson acted without authority. View "Hanson v. State" on Justia Law

Matthew Lewis pleaded guilty to multiple counts of dealing in and possessing depictions of a minor engaged in sexually explicit conduct. He had six prior convictions, three from Washington State and three from South Australia. The inclusion of the South Australian convictions increased his offender score from 6 to 9+, significantly raising the standard range sentence he faced. Lewis challenged the inclusion of these foreign convictions, but the sentencing court rejected his challenges and sentenced him to 102 months on each count, to be served concurrently, followed by 36 months of community custody.Lewis appealed to the Court of Appeals, arguing that "out-of-state convictions" did not include convictions entered in foreign countries. The Court of Appeals rejected his arguments and affirmed his sentence. Lewis then sought review from the Supreme Court of the State of Washington.The Supreme Court of the State of Washington reviewed the case de novo and concluded that the term "out-of-state convictions" in the Sentencing Reform Act (SRA) is ambiguous. The court found no helpful legislative history to clarify the term's meaning. Applying the rule of lenity, which requires ambiguous criminal laws to be construed in favor of the defendant, the court held that "out-of-state" does not include convictions entered in foreign countries. Consequently, the court reversed the Court of Appeals' decision and remanded the case for resentencing without including the South Australian convictions in Lewis's offender score. View "State v. Lewis" on Justia Law

J.W., a 14-year-old, and two other juveniles were involved in an incident where one of the boys exploded a large firework inside a vacant trailer home, causing significant fire and smoke damage. J.W. initially lied to the police about who caused the fire to protect the other juveniles. He later admitted to a juvenile delinquency petition alleging accessory to a crime. The circuit court ordered J.W. and another juvenile to pay restitution of approximately $15,000 for the damage.The Circuit Court of the Seventh Judicial Circuit in Pennington County adjudicated J.W. as a delinquent child and placed him on probation. The court held a restitution hearing and ordered J.W. to pay restitution, finding that the legislative amendments to the juvenile statutes did not require a causal connection between the damages and J.W.'s criminal act. The court determined that the restitution served a rehabilitative purpose and found no credible evidence that the restitution order would cause J.W. serious hardship.The Supreme Court of the State of South Dakota reviewed the case. The court held that the legislative amendments to the juvenile restitution statutes now require a causal connection between the juvenile's criminal act and the victim's damages, similar to adult restitution cases. The court found that J.W.'s act of lying to the police occurred after the damage was done and was not causally connected to the fire damage. Therefore, the court reversed and vacated the circuit court's restitution order, concluding that J.W. was not liable for restitution as the damage did not occur as a result of his criminal act. View "Interest Of J.W." on Justia Law

A defendant was convicted of first-degree felony murder, aggravated child abuse, and sexual battery following the 1992 death of a two-year-old child. The evidence at trial showed that the defendant was alone with the victim, who was later found unconscious, with visible injuries and blood present in the apartment and on the defendant’s clothing. The medical examiner concluded the cause of death was a cerebral hemorrhage from multiple blows to the head. The defendant claimed the child’s injuries were accidental or caused by another individual, but the jury rejected this defense and recommended a death sentence, which was imposed.After the conviction and sentence were affirmed by the Supreme Court of Florida, the defendant filed several postconviction motions and habeas petitions, all of which were denied. In the most recent proceedings, the defendant filed a fourth successive motion for postconviction relief in the Circuit Court for Duval County. The motion argued that microscopic slides from the autopsy constituted newly discovered evidence and that the State had suppressed exculpatory information in violation of Brady v. Maryland. The circuit court summarily denied the motion, finding the claims untimely and without merit, noting that the existence of the slides and the finding of pneumonia were disclosed in the original autopsy report and available to the defense.On appeal, the Supreme Court of Florida reviewed the summary denial de novo. The court held that both the Brady and newly discovered evidence claims were untimely because the defendant knew or could have known of the evidence with due diligence. The court further held that no evidence was suppressed and that the new expert’s conclusions did not meet the standards for materiality or probability of acquittal required for relief. The court affirmed the summary denial of postconviction relief. View "Davis v. State of Florida" on Justia Law

An individual was convicted of the 2010 first-degree felony murder of an elderly woman, Janet Patrick, after being seen with her at a grocery store and later found in possession of her car and credit cards. The victim’s body was discovered in a wooded area, and forensic evidence linked the defendant to the crime scene and the victim’s vehicle. The defendant was also charged with robbery and kidnapping. His defense at trial was based on claims of mental illness or seizures. The jury found him guilty on all counts.The Florida Supreme Court previously affirmed the convictions and non-capital sentences but reversed the death sentence because the jury’s recommendation was not unanimous, as required by Hurst v. State. After subsequent legal developments, including State v. Poole and State v. Okafor, the defendant was granted a new penalty phase. During the new penalty phase, the defendant represented himself, waived a jury trial, and declined to present mitigation evidence. The trial court denied his motion for a continuance to secure a new mitigation specialist, finding that he had been given multiple opportunities to obtain such assistance. The court ultimately sentenced him to death, finding four aggravating factors and several mitigating circumstances.On direct appeal, the Supreme Court of Florida reviewed four claims: denial of the motion to continue, voluntariness of waivers of jury and mitigation, access to discovery, and the constitutionality of Florida’s death penalty scheme. The court held that the trial court did not abuse its discretion in denying the continuance, that the waivers were knowing and voluntary, that discovery obligations were met, and that the capital sentencing scheme was constitutional. The court affirmed the sentence of death. View "Williams v. State of Florida" on Justia Law