Justia Criminal Law Opinion Summaries

Charles Rowe pleaded guilty to three federal crimes and was sentenced to 360 months in prison. He had a prior conviction for cocaine trafficking under Florida law. The district court determined that this prior conviction was a controlled substance offense, triggering a sentencing enhancement under the career offender guidelines. Rowe appealed, challenging the legitimacy of his guilty plea and the enhanced sentence.The United States District Court for the Northern District of Florida accepted Rowe's guilty plea after a thorough plea colloquy conducted by a magistrate judge. The probation office recommended an enhanced sentence under the Armed Career Criminal Act and the career offender guidelines due to Rowe's prior convictions. Rowe objected, arguing that his prior conviction for cocaine trafficking did not qualify as a controlled substance offense. The district court held the sentencing in abeyance pending a decision from the Florida Supreme Court on a related issue. After the Florida Supreme Court's decision, the district court applied the enhanced sentence and sentenced Rowe to 360 months in prison.The United States Court of Appeals for the Eleventh Circuit reviewed the case. The court held that the Florida Supreme Court's decision in Conage II clarified that a conviction for cocaine trafficking under Florida law requires proof of possession with intent to distribute, aligning it with the federal definition of a controlled substance offense under the career offender guidelines. The court concluded that Rowe's prior conviction was a controlled substance offense and upheld the enhanced sentence. The court also found that the district court properly substantiated and accepted Rowe's guilty plea. Consequently, the Eleventh Circuit affirmed Rowe's conviction and sentence. View "United States v. Rowe" on Justia Law

The defendant, Matthew Raymond, was convicted by a jury in the Superior Court on four counts of second-degree assault, six counts of simple assault-domestic violence, one count of false imprisonment, and one count of misdemeanor criminal mischief. The incidents occurred in May and June 2022, but the victim did not report them until August 2022. The defendant was subsequently charged with these offenses.Before the trial, the State intended to call Dr. Scott Hampton, an expert in intimate partner violence, to testify. The defendant moved to exclude Hampton’s testimony, arguing it was unreliable under RSA 516:29-a. The State countered that Hampton would provide general education on domestic violence dynamics without discussing the specific facts of the case. The Trial Court held an evidentiary hearing and found Hampton qualified to offer expert opinions in the field of intimate partner violence, allowing his testimony with limitations. The jury trial proceeded, and the defendant was convicted on most charges, leading to this appeal.The Supreme Court of New Hampshire reviewed the case and upheld the trial court’s decision to admit Hampton’s testimony. The court found that Hampton’s extensive experience and specialized knowledge in domestic violence met the reliability standards under New Hampshire Rule of Evidence 702 and RSA 516:29-a. The court noted that Hampton’s testimony was based on his experience with thousands of domestic violence victims and offenders over two decades, which provided a sufficient basis for his general education testimony. The court also distinguished this case from State v. Keller, where the expert’s methodology was applied to the specific facts of the case. Here, Hampton’s testimony was general and not case-specific, making the RSA 516:29-a, II(a) factors less applicable. Consequently, the court affirmed the trial court’s ruling, finding no reversible error. View "State v. Raymond" on Justia Law

Carl T. Masi was charged with multiple counts of first-degree and second-degree criminal sexual conduct involving three minors, AU, SU, and MU, who alleged that Masi began sexually assaulting them when they started living with him. Masi sought to introduce evidence related to the complainants' sexual histories, specifically that AU had viewed pornography during prior sexual abuse by her uncle. The trial court denied Masi's motion, ruling that this evidence was inadmissible under the rape-shield statute, MCL 750.520j, and People v Morse, because there was no conviction related to the prior abuse.The Michigan Court of Appeals affirmed the trial court's decision, holding that evidence of AU viewing pornography during prior sexual abuse was "sexual conduct" under the rape-shield statute and thus inadmissible under Morse. Masi then sought leave to appeal to the Michigan Supreme Court.The Michigan Supreme Court reviewed the case and held that the plain meaning of "sexual conduct" in the rape-shield statute includes both voluntary and involuntary behavior, thus encompassing nonvolitional acts such as involuntarily viewing pornography during sexual abuse. The Court overruled Morse to the extent that it required a conviction for prior sexual conduct to be admissible. Instead, the Court established a new standard requiring an in camera evidentiary hearing to determine the admissibility of such evidence based on specific factors, including whether the prior act occurred, its similarity to the current allegations, its relevance, necessity to the defense, and whether its probative value outweighs its prejudicial effect.The Michigan Supreme Court affirmed in part and vacated in part the lower courts' decisions and remanded the case to the Macomb Circuit Court to apply the new standard in an in camera hearing. View "People v. Masi" on Justia Law

Joseph Terrell Goody, a documented gang member with a lengthy criminal history, was convicted of possession of a firearm by a felon. His criminal record includes convictions for cocaine possession, robbery, assault, deadly conduct, evading arrest, and burglary. On September 26, 2020, Goody was pulled over for traffic violations, and officers found cocaine, methamphetamine, and a suspicious guitar case in his car. The case contained a loaded rifle. Goody was arrested and later pleaded guilty to violations of 18 U.S.C. §§ 922(g)(1) and 924(a)(2).The United States District Court for the Southern District of Texas sentenced Goody to 57 months of imprisonment and two years of supervised release, with a special condition prohibiting him from associating with gang members. Goody appealed his conviction and the supervised-release condition.The United States Court of Appeals for the Fifth Circuit reviewed the case. Goody raised three arguments on appeal: the facial unconstitutionality of the felon-in-possession ban under the Second Amendment, a violation of the equal protection principle under the Fifth Amendment, and the vagueness of the supervised-release condition. The court rejected all three arguments. It upheld the constitutionality of the felon-in-possession ban, found no merit in the equal protection claim, and determined that the supervised-release condition was not plainly erroneous. The court noted that similar conditions have been routinely imposed and upheld by other courts. Consequently, the Fifth Circuit affirmed the district court's judgment. View "United States v. Goody" on Justia Law

In 2024, the United States District Court for the District of Puerto Rico revoked Kelvin García-Oquendo's terms of supervised release and imposed concurrent terms of 21 months and 18 months of imprisonment. This decision was based on findings that García had violated the conditions of his release by engaging in new criminal conduct, including identity theft and bank fraud.Previously, in 2013, García had pleaded guilty to conspiracy to commit bank fraud and aggravated identity theft, and in 2015, he pleaded guilty to unauthorized use and transfer of access devices. He was sentenced to a total of 89 months' imprisonment and five years of supervised release. In 2023, the Probation Office alleged that García had committed new crimes, leading to his arrest and a preliminary revocation hearing where probable cause was found for some of the allegations.The United States Court of Appeals for the First Circuit reviewed the case. García argued that the District Court erred by admitting hearsay testimony without proper balancing under Federal Rule of Criminal Procedure 32.1(b) and the Due Process Clause. The First Circuit agreed that the District Court erred in admitting the testimony but concluded that the error was harmless due to the strong circumstantial evidence supporting the violation findings. The court held that Rule 32.1's limited confrontation right applies to the entirety of the revocation proceeding, including the determination of post-revocation sanctions. However, it found that any error in considering the hearsay testimony during sentencing was also harmless, as the other evidence strongly supported the District Court's findings.The First Circuit affirmed the District Court's revocation order and sentences. View "United States v. Garcia-Oquendo" on Justia Law

Jadnel Flores-Nater, a member of a gang, participated in the kidnapping and murder of a victim in Puerto Rico. On June 8, 2018, Flores-Nater and four other gang members kidnapped the victim from a public housing complex, each carrying an assault rifle. They drove the victim to a remote area, where Flores-Nater and other gang members shot and killed him. Flores-Nater was charged with kidnapping resulting in death, using a firearm in furtherance of a crime of violence, and using a firearm in furtherance of a crime of violence causing murder. He pleaded guilty to discharging a firearm in furtherance of a crime of violence, and the government agreed to dismiss the other charges.The United States District Court for the District of Puerto Rico initially sentenced Flores-Nater to 360 months in prison, which was above the 120-month guideline and the 300-month recommendation in the plea agreement. Flores-Nater appealed, and the United States Court of Appeals for the First Circuit vacated the sentence, finding it substantively unreasonable due to the district court's failure to articulate a plausible rationale for the upward variance. On remand, the district court again imposed a 360-month sentence, citing the high crime rate in Puerto Rico and the need for deterrence, but did not address Flores-Nater's argument regarding his age at the time of the offense.The United States Court of Appeals for the First Circuit reviewed the case again. The court found that the district court committed procedural error by failing to explain whether and why it rejected Flores-Nater's argument that his youth at the time of the offense should be considered a mitigating factor. The appellate court vacated the sentence and remanded the case for resentencing, requiring the district court to provide a clear explanation of its reasoning, particularly regarding the defendant's age. The court did not find that the government breached the plea agreement by defending the higher sentence on appeal. View "United States v. Flores-Nater" on Justia Law

In 2000, Johnny Lawrence Brinson was convicted of attempted willful, deliberate, and premeditated murder, with firearm use and discharge, and being a felon in possession of a firearm. He was sentenced to 39 years to life in prison. In 2024, Brinson filed multiple requests for recall and resentencing under Penal Code section 1172.1, citing amendments to the Penal Code and Assembly Bill No. 600. The trial court declined to take any action on these requests.Previously, the trial court had affirmed Brinson's conviction and sentence on direct appeal. In 2024, Brinson filed his first request for recall and resentencing, which the court denied. He subsequently filed two more requests, both of which the court also declined to act upon, issuing orders stating no action would be taken pursuant to section 1172.1, subdivision (c). Brinson appealed the court's decision not to act on his requests.The California Court of Appeal, First Appellate District, reviewed the case. The court held that the trial court's decision not to take action on Brinson's request for recall and resentencing is not an appealable order. The court emphasized that under section 1172.1, subdivision (c), a defendant is not entitled to file a petition for resentencing, and the court is not required to respond to such a request. The appellate court agreed with existing case law that a trial court's decision not to act on a defendant-initiated request for recall and resentencing does not affect the defendant's substantial rights. Consequently, the appeal was dismissed. View "People v. Brinson" on Justia Law

Erik Harris, a frequent marijuana user, purchased three pistols over a short period. Each time, he falsely stated on federal forms that he was not an unlawful user of marijuana. After losing one of the guns while intoxicated, Harris reported it stolen and bought a replacement. When the missing gun was found with a felon, Harris admitted to regular marijuana use during police questioning.The United States District Court for the Western District of Pennsylvania denied Harris's motion to dismiss the charges, which included three counts under 18 U.S.C. §922(g)(3) for possessing guns as an unlawful drug user and three counts under §922(a)(6) for lying to obtain the guns. The court concluded that §922(g)(3) was constitutional as applied to Harris, using means-end scrutiny. Harris then pleaded guilty to all counts but preserved his right to appeal the denial of his motion to dismiss.The United States Court of Appeals for the Third Circuit reviewed the case. The court held that history and tradition justify §922(g)(3)’s restrictions on those who pose a special danger of misusing firearms due to frequent drug use. However, the court found insufficient facts to determine whether the law's restrictions are constitutional as applied to Harris. The court affirmed the statute's constitutionality in general but vacated Harris's conviction under §922(g)(3) and remanded the case for further fact-finding. The court also held that §922(g)(3) is not unconstitutionally vague as applied to Harris and upheld his convictions under §922(a)(6) for lying on the federal forms. View "United States v. Harris" on Justia Law

Kevin Johnson was convicted of first-degree murder in 1986 for the killing of Lyndon "Cowboy" Morris, a drug dealer in Philadelphia. Four witnesses identified Johnson as the shooter, with three positively identifying him and one expressing doubts. Johnson claimed mistaken identity and presented an alibi, but his testimony conflicted with his alibi witnesses. The jury convicted him, and he was sentenced to life in prison. The Superior Court affirmed his conviction and sentence.Johnson sought post-conviction relief under the Pennsylvania Post Conviction Relief Act (PCRA), claiming ineffective assistance of counsel and presenting new evidence of witness recantations. The PCRA court denied his petition, but the Superior Court remanded for an evidentiary hearing. After the hearing, the state courts dismissed his petition, and the dismissal was affirmed. Johnson then filed a federal habeas petition, which was pending when new evidence emerged, leading to additional PCRA petitions that were ultimately dismissed as time-barred.The United States District Court for the Eastern District of Pennsylvania reviewed Johnson's federal habeas petition. Johnson and the Philadelphia District Attorney's Office attempted to settle the case by waiving procedural defenses, but the District Court rejected the procedural-default waiver. The court found that Johnson's Brady claims, based on witness recantations and arrest photos, were not material and did not warrant habeas relief. The court also rejected Johnson's ineffective assistance of counsel claims.The United States Court of Appeals for the Third Circuit affirmed the District Court's decision. The court held that the District Court had discretion to reject the procedural-default waiver and that Johnson failed to show cause and prejudice or a fundamental miscarriage of justice to overcome the default. The court also found that Johnson did not qualify for an evidentiary hearing under 28 U.S.C. § 2254(e)(2) and that his remaining Brady and ineffective assistance claims lacked merit. View "Johnson v. Superintendent Mahanoy SCI" on Justia Law

David Valle, an inmate at the California Men’s Colony, was found in possession of a 14-inch by 1-inch sharpened plastic fragment, metal fragments from a shower valve cover, and a folded metal sheet during a cell search. The plastic fragment was described as a weapon resembling a spear or knife. Valle admitted to having the items but claimed he could not remember why.Valle was convicted by a jury of possessing a sharp instrument in prison under Penal Code section 4502. The trial court sentenced him as a third-strike offender to 25 years to life in prison. Valle appealed, arguing that section 4502 is unconstitutionally vague because it does not define "sharp instrument."The California Court of Appeal, Second Appellate District, reviewed Valle's constitutional challenge de novo and rejected it. The court held that section 4502 is not unconstitutionally vague, either facially or as applied to Valle. The court reasoned that the statute's purpose is to protect inmates and prison officials from assaults by armed prisoners and that it provides a clear standard of conduct. The court cited previous California decisions that consistently upheld the statute's constitutionality.The court concluded that a 14-inch by 1-inch sharpened piece of hard, non-flexible plastic is a sharp instrument prohibited by section 4502. Valle's possession of such items, concealed in his cell, demonstrated his understanding that they were prohibited. The judgment was affirmed. View "People v. Valle" on Justia Law