Justia Criminal Law Opinion Summaries

Gerald Williams, an inmate in Louisiana, filed a suit for judicial review after the Louisiana Board of Pardons and Parole revoked his parole. Williams was originally convicted of armed robbery in 1985 and sentenced to 99 years without parole. After serving 28 years, he was released on parole in 2013. In 2021, Williams was arrested for aggravated assault, pleaded guilty to simple assault, and subsequently had his parole revoked. He later claimed his waivers of the revocation hearings were not knowing and voluntary and argued that his parole violation should be considered a "technical violation."The district court dismissed Williams' suit with prejudice, based on a recommendation from a commissioner, for failure to state a claim and because it was perempted under La. R.S. 15:574.11(D). The First Circuit Court of Appeal affirmed the district court's decision.The Supreme Court of Louisiana reviewed the case and addressed three main issues: whether Williams' petition was perempted, whether his procedural due process rights were violated, and whether his parole violation could be classified as a "technical violation." The court found that Williams' petition was perempted as it was filed 507 days after the parole revocation, well beyond the 90-day period allowed by law. The court also determined that Williams' waiver of his revocation hearings was knowing, intelligent, and voluntary, as he had signed and acknowledged the waiver in writing. Lastly, the court held that Williams' parole violation could not be classified as a "technical violation" due to his original conviction for a violent crime and his guilty plea to an intentional misdemeanor directly affecting a person.The Supreme Court of Louisiana affirmed the appellate court's decision to dismiss Williams' petition with prejudice. View "Williams v. Department of Public Safety and Corrections" on Justia Law

D.D., a juvenile, was adjudicated delinquent for committing second-degree rape at the age of fourteen and was committed to the custody of the Office of Juvenile Justice until his twenty-first birthday. Upon release, he was required to register as a sex offender. D.D. challenged the constitutionality of this registration requirement, arguing it violated the Sixth and Eighth Amendments of the U.S. Constitution. The juvenile court denied his motion.D.D. appealed to the Court of Appeal, First Circuit, which affirmed both the adjudication and the denial of his constitutional claims. D.D. then sought review from the Supreme Court of Louisiana, which granted his writ application.The Supreme Court of Louisiana held that the sex offender registration requirement for juveniles does not constitute cruel and unusual punishment under the Eighth Amendment, as it is a civil regulatory measure intended to protect public safety rather than a punitive action. The court also found that the registration requirement does not implicate the Sixth Amendment's right to a jury trial, as juvenile proceedings are fundamentally different from adult criminal trials and do not require a jury trial for due process. The court affirmed D.D.'s adjudication and the denial of his motion to declare the registration requirement unconstitutional. View "In re D.D." on Justia Law

John and Analise Noehl were indicted for second-degree murder and cruelty to a juvenile after their seven-week-old son, D.N., was brought to the hospital with life-threatening injuries, including a skull fracture and healing rib fractures. Hospital staff alerted law enforcement due to the suspicious nature of the injuries. Detectives arrived, spoke with the parents at the hospital, and conducted separate interviews in a nearby room. The interviews were calm, lasted under 20 minutes each, and concluded with the parents being allowed to leave to accompany their child to another hospital.The 19th Judicial District Court granted the defendants’ motion to suppress the statements made during these interviews, finding that the parents were subjected to custodial interrogation without having received Miranda warnings. The court reasoned that the circumstances—such as being directed into a separate room, the presence of a homicide detective, and the officers’ actions—amounted to a significant restraint on the defendants’ freedom. The Louisiana First Circuit Court of Appeal denied the State’s writ application, leaving the suppression in place.The Supreme Court of Louisiana reviewed the case and reversed the trial court’s decision. The court held that, under the objective standard established by United States Supreme Court precedent, the defendants were not in custody for Miranda purposes during the hospital interviews. The court emphasized that the relevant inquiry is how a reasonable person in the suspects’ position would have understood the situation, not the subjective beliefs of the officers or the defendants. Because the interviews were brief, non-coercive, and the parents were free to leave afterward, the court concluded that Miranda warnings were not required. The case was remanded for further proceedings. View "STATE OF LOUISIANA VS. NOEHL" on Justia Law

Thomas Keller, a physician specializing in pain management, was convicted of prescribing controlled substances outside the scope of professional practice. Keller was known for prescribing large quantities of opioids, which led to a federal investigation. During the investigation, agents seized a journal from Keller's residence, which contained patient information and medical notes. Keller was subsequently indicted on federal charges, including unlawfully dispensing controlled substances and health care fraud. He was convicted on four counts of distributing controlled substances outside the scope of professional practice.The United States District Court for the Northern District of California denied Keller's motion to suppress the journal, finding it fell within the scope of the search warrant and was supported by probable cause. The court also declined to hold an evidentiary hearing on the suppression motion, ruling that Keller's allegations did not establish contested issues of fact. Additionally, the court rejected Keller's argument that the charges violated the nondelegation doctrine, holding that the Attorney General's regulations were within the scope of authority delegated by Congress. Keller was sentenced to 30 months in prison and 3 years of supervised release.The United States Court of Appeals for the Ninth Circuit affirmed Keller's conviction and sentence. The court held that the district court did not err in denying the motion to suppress the journal, as it was properly seized under the search warrant. The court also found no abuse of discretion in the district court's decision not to hold an evidentiary hearing. The court upheld the constitutionality of the nondelegation doctrine as applied to Keller's charges. Finally, the court ruled that the district court correctly calculated Keller's sentencing range using the drug conversion ratio found in the Sentencing Guidelines commentary, as it was properly incorporated into the Guidelines. View "United States v. Keller" on Justia Law

Khemall Jokhoo was previously convicted by a jury of multiple offenses, including aggravated identity theft, impersonating a federal officer, and various fraud charges. His sentence was affirmed by the United States Court of Appeals for the Eighth Circuit. After serving his prison term, Jokhoo was found by the United States District Court for the District of Minnesota to have violated the conditions of his supervised release seven times within a month, leading to an additional one-year prison sentence.Jokhoo appealed, arguing that there was insufficient evidence to support the findings that he failed to work regularly and held unapproved employment with fiduciary responsibilities. He also contended that his sentence was substantively unreasonable, claiming the district court imposed it with a focus on retribution.The United States Court of Appeals for the Eighth Circuit reviewed the case and found no error in the district court's determination that Jokhoo failed to work regularly. The court noted that Jokhoo worked only one day during the nearly month-long period and had ample time to secure employment during his pre-release period. The court dismissed Jokhoo's argument that he needed time to find a new job after being terminated, as he should have anticipated the job loss due to violating a supervised release condition.The appellate court also concluded that any potential error in finding that Jokhoo held unapproved employment with fiduciary responsibilities was harmless. The district court did not need this finding to revoke his supervised release, as other uncontested violations were sufficient. Additionally, the court found that the district court's mention of retribution did not affect Jokhoo's sentence, as the primary reason for the sentence was his repeated rule violations.The Eighth Circuit affirmed the district court's decision. View "United States v. Khemall Jokhoo" on Justia Law

In late September 2023, JT Myore was convicted by a District of South Dakota jury of aiding and abetting carjacking and brandishing a firearm during a crime of violence on August 25, 2019, and of robbery on May 3, 2021. In early November 2023, a second jury convicted him of second-degree murder for a separate incident on May 3, 2021. The district court sentenced him to 540 months imprisonment after a consolidated sentencing hearing in February 2024. Myore appealed both convictions and the combined sentence.The district court found sufficient evidence to support the carjacking and brandishing convictions, rejecting Myore’s argument that the government failed to prove he took the vehicle by force or intimidation. The court also upheld the use of acquitted conduct from the May 2021 incident to enhance his sentence. For the second-degree murder conviction, the court instructed the jury on the lesser included offense of voluntary manslaughter, which Myore opposed. The jury found him guilty of second-degree murder.The United States Court of Appeals for the Eighth Circuit reviewed the case. The court affirmed both convictions and the sentence. It held that there was sufficient evidence for the carjacking and brandishing convictions, and that the district court did not err in considering acquitted conduct at sentencing. The court also found no plain error in the jury instructions for the second-degree murder charge, as Myore did not raise heat of passion as a defense. Additionally, the court upheld the obstruction of justice sentencing enhancement, finding that the district court made independent findings that Myore testified falsely at trial. View "United States v. Myore" on Justia Law

George Guldi, a former Suffolk County legislator and disbarred real estate attorney, conspired with his former girlfriend, Victoria Davidson, to deceive a mortgage servicer, Ditech Financial LLC, into wiring them $253,236. The funds did not belong to either of them. A jury convicted Guldi of wire fraud, bank fraud, and conspiracy to commit wire fraud and bank fraud. He was sentenced to 36 months of imprisonment followed by three years of supervised release.The United States District Court for the Southern District of New York oversaw the trial. The jury found sufficient evidence to support the existence of a conspiracy, fraudulent intent, and aiding and abetting. The district court also found no reversible error in its jury instructions on conspiracy, wire fraud, and fraudulent intent. Additionally, the court properly considered Guldi’s medical needs during sentencing.The United States Court of Appeals for the Second Circuit reviewed the case. The court affirmed Guldi’s convictions, finding that sufficient evidence supported the jury’s findings and that the district court did not err in its jury instructions. However, the appellate court concluded that the district court erred in applying a two-offense-level enhancement under the U.S. Sentencing Guidelines for using “sophisticated means” to commit or conceal the offense. The appellate court determined that this procedural error rendered Guldi’s sentence procedurally unreasonable.As a result, the Second Circuit affirmed the judgment of conviction but vacated and remanded Guldi’s sentence for resentencing consistent with its opinion. View "United States v. Guldi" on Justia Law

A man was convicted of capital murder for the deaths of his girlfriend and her unborn child. The case against him was largely circumstantial. He reported finding the victim shot in her home, cooperated with police, and provided an account of his whereabouts, supported by his grandmother. The investigation included analysis of surveillance footage, U-Haul rental records, cell phone data, and forensic evidence, but no direct evidence placed him at the scene. The prosecution’s theory relied on the timing and mileage of a rented U-Haul, similarities between shell casings found at the crime scene and at a friend’s house, and the defendant’s purchase of a firearm and ammunition. The defense pointed to gaps in the evidence, alternative suspects, and the lack of direct forensic links.The Johnson District Court admitted some of the defendant’s statements to police, excluded certain ballistics testimony, and barred evidence of the victim’s past fears of an ex-boyfriend. After a three-week trial, a jury found the defendant guilty, and he was sentenced to life without parole. On appeal, the defendant argued that the prosecutor repeatedly violated the court’s order in limine by discussing excluded ballistics evidence and improperly asserted as fact that disputed evidence was undisputed, among other claims.The Supreme Court of the State of Kansas found multiple instances of prosecutorial error, including repeated violations of the order in limine and improper statements during closing argument that conveyed the prosecutor’s opinion on disputed facts. The court held that these errors were not harmless, given the circumstantial nature of the evidence and the meaningful gaps in the State’s case. Applying the constitutional harmlessness standard, the court concluded there was a reasonable possibility the errors contributed to the verdict. The conviction was reversed and the case remanded for further proceedings. View "State v. Wash " on Justia Law

Jason W. Phipps pled no contest to two felonies and two misdemeanors in 2022. His presentence investigation report calculated a criminal history score of B, which he contested, arguing that his 2010 conviction for criminal threat should not be counted due to a ruling in State v. Boettger that struck down reckless criminal threat as unconstitutional. The district court used the modified categorical approach and concluded that Phipps' conviction was for the intentional version of criminal threat, thus maintaining the B score for sentencing.The Kansas Court of Appeals reviewed the case while the United States Supreme Court issued Counterman v. Colorado, which held that a reckless mens rea is sufficient for a criminal threat conviction. The Court of Appeals determined that Counterman overruled Boettger, making it irrelevant whether Phipps' conviction was for reckless or intentional criminal threat, and affirmed his sentence.The Kansas Supreme Court granted Phipps' petition for review. During the review, Phipps completed his sentence, leading the court to question whether the case was moot. After further briefing, the court concluded that Phipps' release rendered the issues moot and overruled the precedent set in State v. Roat, which allowed for review of moot issues under certain exceptions. The court held that once an issue is determined to be moot, jurisdiction is extinguished, and no prudential exceptions apply. Consequently, Phipps' appeal was dismissed as moot, and the court did not address the merits of the Counterman decision. View "State v. Phipps " on Justia Law

Brian Stubbs was convicted of criminal use of a weapon and interference with law enforcement after an incident where he stabbed Edward McCutcheon with a large kitchen knife. Stubbs arrived uninvited at McCutcheon's apartment, leading to a fight. McCutcheon was seriously injured, and Stubbs fled the scene. Police pursued Stubbs, who ignored commands to stop, leading to his arrest.The Douglas District Court convicted Stubbs of criminal use of a weapon and interference with law enforcement. Stubbs appealed, arguing that the statute under which he was convicted was unconstitutionally vague and that there was insufficient evidence to support his conviction for interference with law enforcement. The Kansas Court of Appeals affirmed the district court's decision, holding that Stubbs lacked standing to challenge the statute's vagueness because he did not show it was vague as applied to his conduct.The Kansas Supreme Court reviewed the case and held that Stubbs had standing to bring an arbitrary-enforcement challenge to the statute. The court explained that such challenges are inherently facial because they dispute the legislature's authority to enact the statute at all. The court found that Stubbs' conviction under the allegedly void statute presented a concrete injury, satisfying the standing requirements.On the merits, the Kansas Supreme Court held that the statute's prohibition on possessing a "dangerous knife" with intent to use it "unlawfully against another" provided adequate enforcement guidelines. The court concluded that the statute did not invite arbitrary or discriminatory enforcement. Additionally, the court found sufficient evidence to support Stubbs' conviction for interference with law enforcement, as the jury could reasonably conclude that Stubbs knowingly obstructed the officer's duties. The court affirmed the judgments of both the Court of Appeals and the district court. View "State v. Stubbs " on Justia Law