Justia Criminal Law Opinion Summaries

The defendant was indicted on multiple charges, including two counts of first-degree murder, stemming from an armed robbery in which two victims were killed and another was left paralyzed. During jury selection at his trial in Cleveland County Superior Court, the State used peremptory challenges to excuse two black female prospective jurors. The defense objected, raising a Batson challenge and arguing that the State’s strikes were racially discriminatory. The trial court heard arguments from both sides, including the State’s race-neutral explanations for the strikes, and ultimately denied the Batson challenge, finding no prima facie case of discrimination.Following his conviction on all charges and sentencing to consecutive life terms plus additional imprisonment, the defendant appealed. The North Carolina Court of Appeals, in a divided decision, found that the trial court had moved past Batson’s first step by soliciting and hearing the State’s race-neutral reasons before ruling. The majority held that this rendered the first step moot and remanded the case for a new Batson hearing under the procedural requirements established in State v. Hobbs, 374 N.C. 345 (2020). The dissent argued that the trial court had not actually proceeded to Batson’s third step and that the first step was not moot.The Supreme Court of North Carolina reviewed whether the Court of Appeals erred in holding Batson’s first step moot and remanding for a new hearing. The Supreme Court held that the mootness exception to Batson’s three-step process is to be applied cautiously and only when the trial court has fully completed all three steps. Because the trial court had clearly ruled at step one and had not proceeded to step three, the Supreme Court reversed the Court of Appeals and remanded for consideration of whether the trial court’s step-one determination was clearly erroneous. View "State v. Wilson" on Justia Law

Law enforcement in New Hanover County received information from a confidential source that the defendant was trafficking and distributing large quantities of cocaine. Based on this tip, Detective Wenk applied for a court order to obtain cell-site location information (CSLI) for the defendant’s phone, along with other investigative tools. The trial court found probable cause and granted the order, allowing law enforcement to monitor the defendant’s CSLI. This data showed the defendant’s phone traveling from Wilmington, North Carolina, to Hayward, California, and back, coinciding with suspected drug trafficking activity. Officers later stopped and searched the defendant’s vehicle, discovering trafficking amounts of cocaine. The defendant was indicted on multiple drug-related charges and moved to suppress the evidence obtained from the CSLI and subsequent searches.The Superior Court of New Hanover County denied the motion to suppress, finding reasonable suspicion supported the order and the vehicle stop. The defendant entered an Alford plea but appealed the suppression ruling. The North Carolina Court of Appeals reversed the trial court’s decision, holding that the order for CSLI was not supported by probable cause as required by the Fourth Amendment, and that the evidence should be suppressed. The appellate court rejected the State’s argument that a statutory good faith exception applied, citing prior precedent that the North Carolina Constitution did not recognize such an exception.The Supreme Court of North Carolina reviewed the case and held that the statutory good faith exception in N.C.G.S. § 15A-974 applies only to evidence obtained in substantial violation of Chapter 15A, not to evidence obtained in violation of constitutional rights. However, the court further held that neither the United States Constitution nor the North Carolina Constitution required exclusion of the CSLI in this case, and formally adopted a good faith exception under the state constitution equivalent to the federal standard. The Supreme Court reversed the Court of Appeals, upholding the trial court’s denial of the suppression motion. View "State v. Rogers" on Justia Law

Eduardo Ulises Martinez was investigated by the U.S. Fish & Wildlife Service after a tip that he was traveling internationally and possibly bringing back ivory. Upon his return to Miami International Airport, Customs and Border Protection found three ivory pieces in his luggage, which he initially denied were ivory. Subsequent searches of his home and business uncovered numerous sculptures containing ivory. Martinez, an experienced art dealer, admitted knowing about the legal requirements to declare ivory imports and exports but had not done so. The government charged him with multiple counts of smuggling ivory into and out of the United States, as well as obstruction of justice for attempting to influence a witness’s testimony and misrepresent the provenance of seized items.The United States District Court for the Southern District of Florida denied Martinez’s pretrial motion to dismiss the smuggling charges, rejecting his argument that the antique and de minimis exceptions to ivory import/export restrictions absolved him of the duty to declare the items. The court also granted the government’s motion in limine to exclude evidence about these exceptions, finding them irrelevant to the smuggling charges. At trial, Martinez was convicted on most counts, except for three on which he was acquitted. His post-trial motions for acquittal and a new trial were denied, and he was sentenced to 51 months’ imprisonment, with the court adopting the government’s valuation of the seized statues.On appeal, the United States Court of Appeals for the Eleventh Circuit affirmed Martinez’s convictions and sentence. The court held that the antique and de minimis exceptions did not eliminate the obligation to declare ivory, and evidence about them was properly excluded. The court also found no error in the exclusion of certain interview statements, the sufficiency of the evidence for obstruction of justice, the government’s closing argument, or the sentencing methodology and valuation. The judgment of the district court was affirmed. View "USA v. Martinez" on Justia Law

Malachi Moon Seals, at age eighteen, posted graphic and violent threats against federal officials and their families on official websites, causing some recipients to request security protection. A grand jury indicted him on twelve counts: six for threatening or retaliating against federal officials under 18 U.S.C. § 115(a)(1), and six for transmitting threats via interstate communications under 18 U.S.C. § 875(c). Seals pleaded guilty to all charges. The probation office calculated an advisory sentencing range of 33 to 41 months’ imprisonment, which made him ineligible for straight probation under the guidelines. Nevertheless, both parties advocated for probation, and the United States District Court for the District of Colorado, with hesitation, sentenced Seals to five years’ probation with special conditions.Shortly after beginning probation, Seals violated its terms by posting new threats online. The probation office petitioned for his arrest, and Seals admitted to the violations. The district court revoked his probation and proceeded to resentence him. At the resentencing hearing, the probation office recommended a sentence at the low end of the original guideline range, and the government supported this recommendation. Defense counsel referenced the Tenth Circuit’s decision in United States v. Moore, but suggested its holding might be reversed. The district court did not apply the Moore framework and instead sentenced Seals to 36 months’ imprisonment under the original guideline range.On appeal, the United States Court of Appeals for the Tenth Circuit reviewed whether the district court erred by not applying the two-step resentencing procedure required by Moore I. The court held that, although the district court plainly erred by not following Moore I’s framework, Seals failed to show that the court was required to impose a 0-month sentence at the first step or that this error was plain. Therefore, the Tenth Circuit affirmed the post-revocation sentence. View "United States v. Seals" on Justia Law

A police officer observed a vehicle late at night on a rural road in Vermont, where the passenger-side wheels of the vehicle left the paved portion of the road twice in quick succession. The road had only a center line and no edge markings. The officer, who had extensive training and experience in detecting impaired driving, interpreted the vehicle’s movements as erratic and indicative of possible impairment. The officer stopped the vehicle, and the driver was subsequently arrested for suspicion of driving under the influence (DUI) and driving with a suspended license. The officer’s observations were recorded on the cruiser’s camera.The defendant moved to suppress the evidence obtained during the stop, arguing that the officer lacked reasonable suspicion to justify the stop. The Vermont Superior Court, Addison Unit, Criminal Division, held a hearing and denied the motion to suppress, finding the officer’s testimony credible and concluding that the observed driving behavior—specifically, the vehicle’s wheels leaving the paved road twice—constituted erratic driving and provided reasonable suspicion of impairment. The defendant then entered a conditional guilty plea to the DUI charge and appealed the denial of her suppression motion to the Vermont Supreme Court. The charge for driving with a suspended license was dismissed with prejudice.The Vermont Supreme Court reviewed the trial court’s factual findings for clear error and considered de novo whether those facts met the legal standard for reasonable suspicion. The Court held that the officer had reasonable and articulable suspicion to stop the defendant based on the totality of the circumstances, specifically the erratic driving observed. The Court affirmed the trial court’s denial of the motion to suppress, concluding that the stop was justified under both the Fourth Amendment and Article 11 of the Vermont Constitution. View "State v. Norton" on Justia Law

Kenneth Evans was observed by police engaging in a hand-to-hand transaction in a vehicle. Upon approaching the vehicle, officers detected the smell of marijuana, searched the car, and found a loaded pistol. Evans admitted to handling the firearm and being on parole. He was subsequently indicted by a federal grand jury for being a felon in possession of a firearm and ammunition, to which he pleaded guilty. Evans had prior felony convictions, including one for aggravated robbery under Ohio law.The United States District Court for the Northern District of Ohio determined that Evans’s prior aggravated robbery conviction qualified as a “crime of violence” under the United States Sentencing Guidelines. This finding increased his advisory sentencing range from 24–30 months to 46–57 months, and the court sentenced him to 57 months’ imprisonment. Evans appealed, arguing that his aggravated robbery conviction should not be considered a crime of violence for sentencing purposes.The United States Court of Appeals for the Sixth Circuit reviewed the district court’s legal determination de novo. The appellate court applied the categorical and modified categorical approaches to compare the elements of Ohio’s aggravated robbery statute, as applied to Evans’s conviction, with the definition of “extortion” in the Sentencing Guidelines. The court concluded that aggravated robbery under Ohio Revised Code § 2911.01(A)(1), when predicated on theft, categorically matches the Guidelines’ definition of extortion and therefore constitutes a crime of violence. The court rejected Evans’s arguments to the contrary and affirmed the district court’s judgment, upholding the increased sentence. The court also granted the government’s motion to take judicial notice. View "United States v. Evans" on Justia Law

A Black man was charged with multiple offenses, including felony false imprisonment, after a domestic violence incident in which his girlfriend alleged he struck her and prevented her from leaving his car. Witnesses observed the girlfriend attempting to exit the moving vehicle and heard shouting. The girlfriend initially told police that the defendant hit her and threatened her if she tried to leave, but later recanted, claiming she fabricated the story out of anger. The prosecution introduced both her initial statements and her recantation at trial. The jury found the defendant guilty of felony false imprisonment and other related charges, but acquitted him of attempted robbery. He admitted a prior conviction, and the trial court imposed a total sentence of nine years and four months, including time for an unrelated prior case.During trial, the defendant’s counsel raised concerns under the California Racial Justice Act (RJA) regarding the racial composition of the jury venire and the prosecution’s peremptory challenge of a Black prospective juror. The Santa Clara County Superior Court denied these motions, finding no evidence of bias or violation of the RJA. At sentencing, the court made comments referencing the defendant’s race and background, but defense counsel did not object to these statements under the RJA.The California Court of Appeal, Sixth Appellate District, reviewed the case. It held that the defendant forfeited his RJA claims on appeal by failing to object to the trial court’s statements at the appropriate time. The court also found no merit in the claim of ineffective assistance of counsel, as there was a conceivable tactical reason for not objecting. Additionally, the appellate court determined that the trial court did not err in failing to instruct the jury on misdemeanor false imprisonment, as there was no substantial evidence to support that lesser offense. The judgment of conviction and sentence was affirmed. View "People v. Wagstaff" on Justia Law

In this case, the petitioner was arrested after an incident in which he was accused of firing a gun into a neighbor’s trailer. Law enforcement recovered evidence at the scene and, following his arrest, the petitioner gave a written statement after being advised of his rights. He was indicted on two counts: shooting into a dwelling and possession of a firearm by a convicted felon. Due to a series of administrative errors, judicial conflicts, and continuances, the petitioner remained incarcerated for over three years before trial. During this period, a key defense witness died. The petitioner repeatedly asserted his right to a speedy trial through pro se motions.The Circuit Court of Tishomingo County, Mississippi, applied the four-factor test from Barker v. Wingo to the petitioner’s speedy trial claim. The court found a violation as to the first count (shooting into a dwelling) but not the second (firearm possession), and dismissed only the first count. The petitioner was tried and convicted on the remaining count and sentenced as a habitual offender. The Mississippi Court of Appeals affirmed, holding that the speedy trial right could be analyzed and remedied on a count-by-count basis in a multi-count indictment. The Mississippi Supreme Court and the United States Supreme Court denied further review.The United States Court of Appeals for the Fifth Circuit reviewed the case on habeas corpus. The court held that, under clearly established federal law as determined by the Supreme Court, when a speedy trial violation is found, the only permissible remedy is dismissal of the entire indictment, not just the affected count. The Fifth Circuit concluded that the Mississippi appellate court’s approach was an unreasonable application of federal law. The judgment of the district court was reversed, and the case was remanded with instructions to grant the writ of habeas corpus. View "Berryman v. Huffman" on Justia Law

The defendant was indicted in 2017 on multiple federal charges related to the online enticement of minors and child pornography. He and the government jointly requested a psychiatric evaluation due to his autism and developmental history. Two competency hearings were held, one in 2019 and another in 2021, with expert testimony from psychologists and psychiatrists. The experts agreed he was autistic, but disagreed on his competency to stand trial. The defense argued that his autism and related impairments rendered him unable to understand the proceedings or assist in his defense, while government experts found him competent.After the first hearing, the magistrate judge recommended finding the defendant incompetent, but the United States District Court for the Middle District of Florida rejected this recommendation and found him competent, emphasizing his ability to understand the legal process and consult with counsel. The defendant later signed a plea agreement but requested a second competency hearing before entering a guilty plea. At the second hearing, new expert testimony was presented, and the magistrate judge recommended finding him competent. The district court adopted this recommendation, overruled the defendant’s objections, and accepted his guilty plea, sentencing him to 156 months in prison.On appeal to the United States Court of Appeals for the Eleventh Circuit, the defendant argued that the lower courts erred by placing the burden of proving incompetency on him and that the evidence showed he was not competent. The Eleventh Circuit held that the allocation of the burden of proof was immaterial because the evidence was not in equipoise; the district court’s finding of competency was not clearly erroneous. The court also rejected the argument that a higher standard of “decisional competency” applied, affirming that the correct standard was the ability to understand the proceedings and assist in the defense. The conviction was affirmed. View "USA v. Marks" on Justia Law

Law enforcement discovered that an individual had stored child pornography in a Dropbox account, including videos of him sexually abusing two minor girls and other illicit material. The investigation revealed that the Dropbox account was used for personal file storage, with no evidence of sharing or distribution. The defendant was charged with two counts of sexual exploitation of a child and two counts of possession of child pornography, each count corresponding to a different victim. He pleaded guilty to all charges before trial, and the United States Probation Office prepared a pre-sentence report recommending a lengthy prison term.The United States District Court for the Eastern District of Oklahoma adopted the pre-sentence report and sentenced the defendant to concurrent prison terms totaling 292 months, followed by a lifetime of supervised release. Among the special conditions imposed was a restriction prohibiting the defendant from using the Internet or any online computer services without prior written approval from his probation officer. The court did not provide a specific explanation or analysis for imposing this Internet use condition. The defendant did not object to this condition at sentencing but appealed, arguing that the district court erred by failing to analyze whether the condition satisfied the statutory requirements under 18 U.S.C. § 3583(d).The United States Court of Appeals for the Tenth Circuit reviewed the case for plain error. The court held that the district court plainly erred by imposing the Internet use condition without providing any explanation or analysis as required by law. The Tenth Circuit found that this error was clear under established precedent, affected the defendant’s substantial rights, and seriously affected the fairness and integrity of the proceedings. Accordingly, the Tenth Circuit vacated the sentence and remanded the case for resentencing consistent with its opinion. View "United States v. Bycroft" on Justia Law