Justia Criminal Law Opinion Summaries

The appellant was serving an eight-year federal sentence for threatening to murder an FBI agent. As he neared the end of his sentence, he sent letters from prison threatening an Assistant U.S. Attorney, the prosecutor’s family, and another FBI agent. These communications included vivid descriptions of violent acts and references to his own mental state. A grand jury in the District of Columbia indicted him for these new threats, and his pretrial detention continued even after his prior sentence expired.The United States District Court for the District of Columbia ordered a psychological evaluation to determine the appellant’s competency and potential mental illness, particularly regarding his capacity to conform his conduct to the law. The evaluation found him competent to stand trial but unable to conform his actions to legal requirements due to a delusional disorder. The government then moved to dismiss the indictment without prejudice, citing the likelihood of a valid insanity defense, and requested that the appellant be evaluated for civil commitment under 18 U.S.C. § 4246. The district court dismissed the charges, stayed the dismissal, and ordered that the appellant remain at the federal facility for up to forty-five days for a dangerousness evaluation by the facility’s director.The United States Court of Appeals for the District of Columbia Circuit reviewed whether the district court had authority to order the facility director to conduct a dangerousness evaluation before deciding to issue a certificate under § 4246. The appellate court held that such an order was proper, as it ensured the statutory process was followed and did not contradict any statutory or procedural requirements. The court affirmed the district court’s order, concluding that the stay and evaluation were reasonable and within the court’s inherent powers. View "USA v. Williamson" on Justia Law

The case involves the criminal prosecution of a defendant who was convicted by a jury of second degree assault and use of a deadly weapon to commit a felony. The incident took place in December 2023 at an apartment complex where the defendant, after an intoxicated and unwelcome visit to his cousin’s apartment, became involved in a confrontation with a neighbor. Testimony established that the neighbor attempted to use a baseball bat to keep the defendant away, resulting in a physical altercation. The neighbor suffered multiple injuries, and there was evidence of an escalating struggle, including the neighbor retrieving a shotgun and a fight over the weapon. Both parties claimed self-defense, and the defendant testified to a different version of the events, stating that he was attacked first and responded only to defend himself.After the jury returned guilty verdicts, the District Court for Scotts Bluff County sentenced the defendant to concurrent prison terms. The defendant, represented by new counsel on appeal, challenged the sufficiency of the evidence and raised several claims of ineffective assistance of trial counsel before the Nebraska Court of Appeals. The appellate brief listed alleged failures by trial counsel, such as not subpoenaing certain witnesses, failing to introduce beneficial evidence, not advising the defendant about attending a deposition, inadequately pursuing a plea deal, and poor trial preparation. However, the Court of Appeals found most claims of ineffective assistance were too vague or lacked necessary specificity in the assignments of error, except for the plea agreement issue, which could not be resolved on the record.The Nebraska Supreme Court reviewed the case. It held that the evidence was sufficient for a rational jury to convict, rejecting the self-defense claim as a matter for the jury. The court clarified that claims of ineffective assistance of counsel must be specifically stated in the assignments of error; general or vague claims are procedurally barred. The Supreme Court affirmed the decision of the Court of Appeals. View "State v. Rupp" on Justia Law

The case concerns an engineer who worked for a microchip design company. While employed, he downloaded proprietary design files, including a file for a microchip known as the HMC1022A, and retained them after leaving his employer. Shortly after his departure, he started a competing business that marketed and sold microchips bearing strong similarities to his former employer’s products, using some of the appropriated design files in the manufacturing process. He concealed the origins of these files by renaming them and sought to keep his new business secret from his former employer.A federal grand jury indicted him on a range of charges, including possession of stolen trade secrets, wire fraud, export violations, visa fraud, and unlawful procurement of citizenship. The United States District Court for the District of Massachusetts presided over the jury trial. The defendant was convicted on only one count: unlawful possession of a trade secret, specifically the design layout and GDS file for the HMC1022A microchip. He was acquitted of all other charges, and the court dismissed related charges against his business partner and spouse. Post-trial, the defendant moved to dismiss the indictment, arguing selective enforcement and prosecution on the basis of his Chinese ethnicity, but the district court denied these motions.Upon review, the United States Court of Appeals for the First Circuit affirmed the conviction. The court held that there was sufficient evidence for a reasonable jury to find that the file in question was both a trade secret and that the defendant knew it to be so. The court also affirmed the district court’s rejection of the selective prosecution and enforcement claims, determining that the defendant had not shown similarly situated individuals of a different race were treated differently, nor that the investigation or prosecution was motivated by discriminatory purpose. The conviction and sentence were therefore upheld. View "United States v. Yu" on Justia Law

A man was charged with three counts of possession of a firearm by a convicted felon after parole officers found three guns in the house where he was living with his family. Two days before the search, a parole officer had warned him that no guns could be present in the home after he said a gun was still in the house following a home invasion in which his son was shot. During the search, officers found one gun in a dresser drawer in the master bedroom, another under a mattress in the daughter’s bedroom, and a third in the cushions of the living room couch. Family members testified at trial that the guns belonged to them or their guests and that the defendant was unaware of their presence.A jury found the defendant guilty of attempted possession of a firearm by a convicted felon for the gun in the master bedroom and guilty of possession of a firearm by a convicted felon for the gun found in the living room couch. He was acquitted on the count related to the gun found in the daughter’s bedroom. The 26th Judicial District Court sentenced him to concurrent terms of imprisonment and fines. The Louisiana Court of Appeal, Second Circuit, affirmed the convictions and sentences, except for the fines, which it remanded for further consideration of the defendant’s ability to pay.The Supreme Court of Louisiana granted certiorari to review whether the evidence was sufficient to support the convictions. Applying the standard from Jackson v. Virginia, the court held that the evidence was insufficient to prove beyond a reasonable doubt that the defendant had the requisite intent to constructively possess either firearm. The court found no evidence that the defendant exercised dominion or control over the firearms or was aware of their presence. As a result, the Supreme Court of Louisiana reversed the defendant’s convictions and sentences. View "STATE OF LOUISIANA VS. WHITE" on Justia Law

Drug task force officers in West Virginia observed a car with expired registration, dark window tint, and a malfunctioning taillight, driven by Cornelious Johnson—an individual known to them from a prior drug conviction and currently on federal supervised release. The officers watched as Johnson and his passenger interacted with a man, Jackie Byrd, at an apartment complex previously associated with drug investigations. Although the officers suspected a drug transaction, they did not witness any exchange of items. Shortly after, Tremayne Hawkins entered the back seat, and the car left the complex. Officer Stanley, informed by the task force, stopped the car for the observed traffic violations and, suspecting drug activity, separated and questioned the occupants about their interaction with Byrd. Citing minor inconsistencies in their answers, Stanley called for a K9 unit, which alerted to drugs. A subsequent search yielded a firearm on Hawkins, who admitted to being prohibited from possessing one due to a prior conviction.The United States District Court for the Northern District of West Virginia denied Hawkins’ motion to suppress the firearm, holding that the officers had reasonable suspicion to extend the stop based on the area’s reputation, Johnson’s prior conviction, the observed interaction with Byrd, and the inconsistent statements from the occupants.The United States Court of Appeals for the Fourth Circuit reviewed the district court’s legal conclusions de novo and its factual findings for clear error. The Fourth Circuit held that none of the cited factors—alone or in combination—provided reasonable suspicion to extend the stop. The court emphasized that presence in an area associated with prior investigations, a dated conviction, innocuous interactions, and minor, reconcilable inconsistencies in statements did not collectively amount to reasonable suspicion of criminal activity. Accordingly, the Fourth Circuit reversed the district court’s denial of the suppression motion and remanded the case for further proceedings. View "US v. Hawkins" on Justia Law

Jerome Brown was indicted after law enforcement discovered over thirteen kilograms of fentanyl, a handgun, ammunition, and a large sum of cash in his car, home, and storage unit during a drug-trafficking investigation near Pittsburgh, Pennsylvania. After his arrest, Brown confessed to the offenses. Rather than proceed to trial, he entered into plea negotiations with the government.The parties initially presented a plea agreement to the United States District Court for the Western District of Pennsylvania recommending a sentence of 180 months, the mandatory minimum. The District Court rejected this agreement, finding it inconsistent with the Sentencing Guidelines and the statutory sentencing factors. The parties then negotiated a second agreement for a 198-month sentence, which the District Court also rejected, instead proposing its own sentence of no less than 235 months. Brown, after consulting with counsel, opted to plead guilty without a plea agreement, understanding the District Court’s sentencing position. He was ultimately sentenced to 235 months’ imprisonment with ten years of supervised release.On appeal, the United States Court of Appeals for the Third Circuit considered whether the District Court’s involvement in plea negotiations, in violation of Federal Rule of Criminal Procedure 11(c)(1), required vacatur of Brown’s guilty plea. The Court found that the District Court had improperly participated in plea discussions. However, applying plain error review, the Third Circuit held that Brown failed to demonstrate that this error affected his substantial rights because the record showed he intended to plead guilty regardless of the court’s actions. The Court also rejected Brown’s constitutional challenge to his firearm conviction, noting binding precedent that forecloses his argument. The Third Circuit affirmed the District Court’s judgment. View "USA v. Brown" on Justia Law

In 1995, a military veteran was convicted of assaulting and causing the death of his four-month-old daughter, resulting in a 15-years-to-life sentence for a violation of California Penal Code section 273ab. This was his first and only felony conviction, although he had a prior record of mostly DUI offenses. Nearly three decades later, in 2024, he petitioned for resentencing under Penal Code section 1170.91, arguing that military service-related conditions—specifically traumatic brain injury and substance abuse—were not considered as mitigating factors at his original sentencing.The Superior Court of Solano County initially denied his habeas corpus petition, noting that relief was available through section 1170.91 and instructing him to file a separate resentencing petition. When he subsequently filed a formal resentencing petition under section 1170.91, the trial court summarily denied it without a hearing, stating he had failed to make a prima facie case for relief. The defendant appealed, asserting he was entitled to a public hearing on his petition and that his military-related conditions should have been considered.The California Court of Appeal, First Appellate District, Division Four, reviewed the case. The court held that, even assuming the petition was sufficient to require a public hearing, any procedural error was harmless because the defendant was statutorily ineligible for resentencing. The court concluded that under section 1170.91, subdivision (c), individuals convicted of offenses listed as “super strikes” under section 667, subdivision (e)(2)(C)(iv)—which includes the defendant’s conviction—are categorically excluded from resentencing relief. The court affirmed the denial of the petition, holding that the statutory exclusion applies regardless of whether the conviction was a first offense or resulted from the Three Strikes law. View "P. v. Harrison" on Justia Law

Reggie Matthews was convicted of capital murder for killing Tiana Robinson, with whom he had a tumultuous and abusive relationship. In the year leading up to Robinson’s death, Matthews demonstrated escalating threats, including refusing to leave Robinson’s home, making armed threats, and being reported for prowling near her residence shortly before the murder. On September 6, 2023, at a barbecue in Osceola, Arkansas, Matthews arrived, pursued Robinson as she attempted to flee, and shot her multiple times in the back. Multiple eyewitnesses identified Matthews as the shooter. After the crime, Matthews was arrested and made statements to police following a brief invocation of his right to counsel.In the Mississippi County Circuit Court, Matthews challenged his conviction on several grounds. He argued that the evidence was insufficient to support the verdict, that his statements to police should have been suppressed after he invoked his right to counsel, that a police officer’s unsolicited reference to a bystander’s identification violated a pretrial order and required a mistrial, and that allowing an officer to testify about Matthews’s interrogation violated the best-evidence rule. The circuit court denied his motions for a directed verdict, suppression, and a mistrial, and allowed the officer’s testimony. Matthews was found guilty and sentenced to life without parole.On appeal, the Supreme Court of Arkansas reviewed each of Matthews’s claims. The court held that substantial evidence supported the jury’s verdict, as multiple eyewitnesses identified Matthews as the shooter and his actions demonstrated premeditation and deliberation. The court determined that Matthews’s post-arrest statements were admissible because he reinitiated communication with police after requesting counsel. The court also found no abuse of discretion in denying a mistrial and held that the best-evidence rule was not violated since the recording was admitted. The Supreme Court of Arkansas affirmed Matthews’s conviction and sentence. View "MATTHEWS V. STATE OF ARKANSAS" on Justia Law

The case concerns the December 26, 2020, shooting death of Shaletian Larry. The defendant, Lazarus Reaves, and Larry were in a relationship marked by repeated abuse, as shown by text messages, witness testimony, and prior police involvement. On the day of the incident, after an argument and an altercation in the car, several witnesses observed Larry attempting to escape from her moving vehicle before Reaves shot her in the back and left her on the roadside. Physical evidence, including blood in the car and a firearm linked to Reaves and Larry, supported the prosecution’s case.The Washington County Circuit Court convened a jury trial. The State presented its evidence, after which Reaves moved for a directed verdict on the capital murder and tampering charges, arguing insufficient proof of premeditation. The motion was denied by the circuit court judge. Reaves did not present any evidence in his defense. The jury found him guilty of both charges, and he was sentenced to life imprisonment without parole for capital murder and a concurrent six-year term for tampering with evidence.On appeal, the Supreme Court of Arkansas reviewed whether the evidence was sufficient to support the conviction for capital murder, specifically the element of premeditation and deliberation. The court held that, even with only a single gunshot wound, substantial evidence existed to support the jury’s finding of premeditated and deliberated intent to kill, based on the circumstances of the crime and Reaves’s prior conduct and threats. The court affirmed the conviction and the judgment of the Washington County Circuit Court. View "LAZARUS REAVES V. STATE OF ARKANSAS" on Justia Law

A man was convicted in 2014 of multiple sex crimes, including rape and sodomy, against a single victim. The prosecution’s case at trial relied on the victim’s testimony, testimony from eyewitnesses who interacted with the victim immediately after the incident, medical and forensic evidence, and a codefendant’s statements. The defendant testified, asserting that the sexual activity was consensual but admitting to having lied to police. The jury found him guilty of several charges, and he was sentenced to 575 months in prison. The Court of Appeals affirmed his convictions, and the Oregon Supreme Court declined review.Subsequently, the defendant pursued post-conviction relief in Marion County Circuit Court, first on various grounds (without asserting actual innocence), and later, in a second petition, on the basis of newly discovered evidence—a sworn recantation by the victim stating that the sexual acts had been consensual and her prior testimony was false. The state moved to dismiss this second petition, arguing that Oregon’s Post-Conviction Hearing Act (PCHA) does not recognize “actual innocence” as a standalone ground for relief. The post-conviction court agreed and dismissed the petition with prejudice, finding no authority for a freestanding innocence claim.The petitioner then sought mandamus relief from the Supreme Court of the State of Oregon, asking it to direct the lower court to vacate its dismissal. The Oregon Supreme Court held that the PCHA does not provide a remedy for claims based solely on newly discovered evidence, such as a recantation, unless there is an allegation that the prosecution knowingly presented or failed to correct false testimony. Because the petitioner did not allege prosecutorial misconduct, the court concluded the post-conviction court was not required by law to deny the state’s motion to dismiss. Accordingly, the Supreme Court of Oregon dismissed the alternative writ of mandamus. View "Perkins v. Fhuere" on Justia Law