Justia Criminal Law Opinion Summaries

Law enforcement officers executed a search warrant at a residence where a firearm was discovered in a bag containing the defendant’s identification and two loaded magazines. The defendant was present in the bedroom with the bag and was on parole for a prior state offense. DNA swabs taken from the firearm, along with a sample from the defendant, were analyzed by the Pennsylvania State Police Crime Laboratory, which identified multiple DNA contributors but could not conclusively match the DNA to the defendant. The DNA evidence was then submitted to a private company using TrueAllele probabilistic genotyping software, which calculated an extremely high likelihood ratio indicating the DNA was much more likely to include the defendant as a contributor.The defendant moved to exclude the TrueAllele evidence in the United States District Court for the Middle District of Pennsylvania, arguing it was unreliable under Daubert v. Merrell Dow Pharmaceuticals, Inc. and Rule 702 of the Federal Rules of Evidence. After a two-day Daubert hearing featuring expert testimony from both sides, the District Court found that the government met its burden to demonstrate the reliability of TrueAllele and denied the motion to exclude. The District Court also rejected the defendant’s motion to dismiss the indictment on Second Amendment grounds. The defendant ultimately pleaded guilty, preserving his right to appeal these rulings, and was sentenced to 78 months of imprisonment, consecutive to an anticipated state sentence.On appeal, the United States Court of Appeals for the Third Circuit reviewed the District Court’s Daubert ruling for abuse of discretion and its Second Amendment analysis de novo. The Third Circuit held that TrueAllele’s methodology was sufficiently reliable for admissibility, finding that it satisfied factors such as testability, low error rates, presence of governing standards, peer review, and general acceptance in the relevant scientific community. The Court also affirmed the District Court’s rejection of the defendant’s constitutional and sentencing challenges, and the judgment was affirmed. View "USA v. Anderson" on Justia Law

A noncitizen defendant was charged in 2015 with serious felonies, including assault with intent to commit rape, following a single incident. He faced nearly certain deportation if convicted, as his charges qualified as “aggravated felonies” under federal immigration law. Initially represented by a public defender, the defendant later retained new counsel and proceeded to trial, ultimately being convicted on all counts in 2017. During plea negotiations, the prosecution required any deal to include prison time, sex offender registration, and a “strike,” but no immigration-safe plea was pursued. Notably, after the defendant changed attorneys, a federal appellate decision altered the immigration consequences for certain California offenses, making immigration-neutral pleas possible.After completing his sentence, the defendant filed a motion under California Penal Code section 1473.7 to vacate his conviction, arguing that he did not meaningfully understand the dire immigration consequences of conviction and would have sought an immigration-safe plea had he been properly advised. The Superior Court of Riverside County denied the motion, finding the defendant was ineligible for relief because his conviction was final before the current statutory amendment applied, and concluding he would not have accepted a plea in any event.On appeal, the Court of Appeal of the State of California, Fourth Appellate District, Division Two, reversed. The appellate court held that Penal Code section 1473.7 relief is available for final convictions, including those after trial, and found that the defendant did not meaningfully understand the immigration consequences. The court further held there was a reasonable probability he would have pursued an immigration-safe plea, and that such a plea would likely have been accepted by the prosecution and trial court. The appellate court remanded with instructions to grant the motion and vacate the conviction. View "P. v. Avena" on Justia Law

A defendant accessed the internet using a publicly available Wi-Fi network operated by a local business, A&W, located near his home. Access to the Wi-Fi required users to acknowledge terms of service that, among other things, stated A&W did not actively monitor the network but could cooperate with legal authorities and disclose users’ activities in response to lawful requests. After A&W’s owner and their consultant noticed suspicious activity flagged by their firewall, they informed law enforcement, which then directed A&W to monitor and log the defendant’s internet activity for approximately one year. This surveillance included tracking over 255,000 webpage visits and collecting packet capture data. Information obtained through this monitoring led to the defendant’s identification, arrest, and conviction on charges of encouraging child sexual abuse.The case was first heard in the Lane County Circuit Court, where the defendant moved to suppress evidence obtained from the year-long monitoring. The trial court found A&W’s owner and consultant acted as state agents but ruled that the defendant had no protected privacy interest in his use of the public Wi-Fi network, and denied the suppression motion. After a stipulated facts trial, the court convicted the defendant. On appeal, the Oregon Court of Appeals affirmed, holding that the defendant did not have a constitutionally protected privacy interest in his internet browsing activities on the public network under the circumstances.The Supreme Court of the State of Oregon reversed the decision of the Court of Appeals in part, and reversed the judgment of the circuit court, remanding the case for further proceedings. The Supreme Court held that under Article I, section 9, of the Oregon Constitution, a person retains a right to privacy in their internet browsing activities even when accessing the internet via a public network, and that acknowledging terms of service like those present did not eliminate that privacy right. The year-long warrantless monitoring constituted a “search,” and the State failed to justify the lack of a warrant. View "State v. Simons" on Justia Law

A woman was found dead in a Seattle park in 1998. The victim, who worked as a sex worker, had been strangled, sexually assaulted, and robbed. DNA evidence from the crime scene went unmatched for several years until, in 2004, it was linked to John Ray Stearns, who was serving time for another offense. Although probable cause existed at that time, charges were not filed until 2016. At trial, the State introduced evidence of two prior sexual assaults committed by Mr. Stearns, arguing these acts were sufficiently similar to show a common scheme or plan and to rebut his claim of consent.Following a first trial that ended in a hung jury, Mr. Stearns was convicted at retrial in King County Superior Court. On appeal, Division One of the Washington Court of Appeals initially reversed the conviction on the grounds of preaccusatorial delay but, after the Washington Supreme Court reversed and remanded, the Court of Appeals addressed remaining issues. The appellate court concluded that the trial court erred by admitting evidence of prior bad acts under the common scheme or plan exception to ER 404(b) and reversed in part.The Supreme Court of the State of Washington reviewed whether the trial court abused its discretion in admitting evidence of prior sexual assaults. The court held that the trial court did not abuse its discretion: the prior acts were markedly similar to the charged crime, and the victims and circumstances were sufficiently similar to support admission under the common scheme or plan exception. The Supreme Court clarified that the test does not require markedly similar victims, only sufficient similarities in acts and circumstances. The court also found no abuse of discretion in the trial court’s prejudice analysis. The Supreme Court reversed the Court of Appeals and reinstated Mr. Stearns’ conviction. View "State v. Stearns" on Justia Law

This case involves a defendant who was charged with four counts of rape involving three victims. Each victim testified that they did not consent to sexual activity with the defendant, and their decisions to report the assaults were interconnected—one victim’s report influenced another’s decision to come forward, and the relationships among the victims were relevant to the timing and manner of their disclosures. The defendant maintained that all sexual encounters were consensual.Before trial, the defendant repeatedly moved to sever the charges into separate trials, arguing that joinder would unfairly prejudice him. The Superior Court for Snohomish County denied these motions, finding that the charges were properly joined because they were of the same or similar character and involved related events and witnesses. The court determined that the evidence on each count was similarly strong, that the defenses were clear and substantially the same, that the jury could be properly instructed to consider each count separately, and that much of the evidence would be cross-admissible due to the interconnectedness of the victims and their reports. The jury convicted the defendant on all counts.The Washington Court of Appeals reversed the convictions, holding that the trial court abused its discretion by not severing the charges. On review, the Supreme Court of the State of Washington applied the abuse of discretion standard and concluded that the trial court had properly weighed the relevant factors. The Supreme Court held that, while not all evidence would have been cross-admissible in separate trials, the prejudice did not outweigh the benefits of joinder given the overlapping witnesses and related circumstances. Therefore, the Supreme Court reversed the Court of Appeals and remanded for further proceedings consistent with its opinion. View "State v. Krause" on Justia Law

Michael Johnson was charged with murder in connection with a death where the cause was disputed and involved conflicting evidence regarding physical injuries and substance use. At trial, Johnson’s counsel requested that the jury receive an instruction on the lesser-included offense of homicide by assault. However, the instruction given, which was drafted and approved by Johnson’s counsel, mischaracterized the required mens rea for homicide by assault. The jury convicted Johnson of intentional murder.On appeal, Johnson did not argue that his counsel was ineffective for proposing the erroneous instruction, nor did he claim the trial court committed plain error. Despite this, the Utah Court of Appeals raised the instructional error sua sponte and, applying the exceptional circumstances exception, found the error prejudicial and reversed the conviction. The Supreme Court of the State of Utah granted certiorari and reversed the Court of Appeals, holding that it was improper to address the instructional error under the exceptional circumstances exception since it had not been preserved or raised by the parties. The case was remanded, and the Court of Appeals summarily affirmed Johnson’s conviction.Johnson then sought postconviction relief, arguing his trial and appellate counsel were ineffective for failing to challenge the jury instruction. The Third District Court found deficient performance but concluded Johnson suffered no prejudice because the instruction’s first element required the jury to rule out murder before considering the lesser offense. Since the jury convicted on murder, the court found no reasonable probability of a different outcome.The Supreme Court of the State of Utah affirmed, holding that its prior decision vacated the Court of Appeals’ prejudice analysis, leaving the district court free to make its own ruling. It further held that Johnson could not establish prejudice, as the unchallenged first part of the instruction precluded conviction on the lesser offense once the jury found murder. View "Johnson v. State" on Justia Law

In 2003, Robert Arnett was convicted in Pennsylvania for engaging in sexual activity with a fourteen-year-old, resulting in his plea of guilty to several offenses, including aggravated indecent assault and statutory sexual assault. He received a sentence of five to ten years’ incarceration. At the time, Pennsylvania’s sexual offender law—known as Megan’s Law—required Arnett to register as a sexual offender for life. After Arnett’s release, the law was replaced by successive statutes, culminating in the Sexual Offender Registration and Notification Act II (SORNA II), which continued to require his lifetime registration. Arnett, more than fifteen years after his sentence became final, filed a pro se petition under the Post Conviction Relief Act (PCRA), later amended by counsel, challenging SORNA II’s constitutionality.The York County Court of Common Pleas considered Arnett’s PCRA petition, holding a hearing without witness testimony. The court found SORNA II unconstitutional as applied to Arnett, granted his petition, and enjoined enforcement of the registration requirements. The Commonwealth appealed. The Superior Court determined that constitutional challenges to SORNA fall within the exclusive jurisdiction of the Supreme Court of Pennsylvania and transferred the appeal accordingly.The Supreme Court of Pennsylvania reviewed whether the PCRA is a proper mechanism for challenging the constitutionality of a non-punitive sexual offender registration statute like SORNA II. The court held that the PCRA, by its plain terms, is limited to challenges related to a conviction or sentence and does not provide a vehicle for relief from non-punitive collateral consequences such as SORNA II’s registration requirements. The court vacated the lower court’s order granting relief, dismissed Arnett’s petition under the PCRA, and declined to address whether other mechanisms—such as habeas corpus—may be used to challenge SORNA II, reserving that question for future cases. View "Commonwealth v. Arnett" on Justia Law

The case concerns a petitioner who, after entering an Alford plea to a charge of lewd and lascivious conduct with a minor and receiving a sentence of twenty years with ten years fixed, unsuccessfully challenged the sentence as excessive on direct appeal. The Idaho Court of Appeals affirmed his conviction and sentence. Subsequently, the petitioner filed a pro se petition for post-conviction relief, raising several "trial-error" claims—including Miranda violations, excessive bail, breach of a prior plea agreement, insufficient evidence, and falsification of the probable cause affidavit—and a claim of ineffective assistance of counsel based on multiple alleged deficiencies. Post-conviction counsel was appointed but did not amend the petition. The State moved for summary disposition, addressing only the ineffective assistance claim, not the trial-error claims.The District Court for the First Judicial District summarily dismissed the entire petition. It ruled that the trial-error claims were procedurally barred because they could have been raised on direct appeal, and found the ineffective assistance claim unsupported by admissible evidence or clearly disproven by the record. The Idaho Court of Appeals affirmed, holding that the petitioner failed to preserve his lack-of-notice challenge regarding the trial-error claims by not seeking reconsideration.The Supreme Court of the State of Idaho reviewed the case. It held that the district court erred by dismissing the trial-error claims on grounds not raised by the State and without providing the required twenty-day notice and opportunity to respond under Idaho Code section 19-4906(b). The court clarified that such lack-of-notice claims may be raised for the first time on appeal. However, the court affirmed the dismissal of the ineffective assistance of counsel claim, finding that the State’s motion sufficiently put the petitioner on notice and the district court’s reasoning was not sua sponte. The case was affirmed in part, reversed in part, and remanded. View "Best v. State" on Justia Law

A 12-year-old seventh-grade student was accused by a classmate of inappropriate touching at school. The following day, two police officers, neither previously known to the student, removed him from class for questioning. The first interrogation took place in a small, closed office used by the school resource officer, with one officer questioning the child and another, fully uniformed and armed, standing in front of the door. No Miranda warnings were given, and the student was not told he could leave, refuse to answer, or contact his parents. He eventually admitted that he may have accidentally touched the other student. Less than an hour later, questioning continued in a school suspension cubicle, where multiple authority figures, including the officers and an assistant principal, stood around him and asked more direct questions, resulting in a similar admission.The State charged the student with Fourth Degree Sexual Assault. Before trial in the Manitowoc County Circuit Court, the student sought to suppress his statements to law enforcement, arguing violations of Miranda v. Arizona and involuntariness. The circuit court denied suppression, finding the interrogations non-custodial and voluntary. After a bench trial, the court adjudicated the student delinquent. The Wisconsin Court of Appeals affirmed, holding that Miranda did not apply because the student was not in custody and that his statements were voluntary.The Supreme Court of Wisconsin reviewed the case. It concluded that the student was in custody for Miranda purposes during both interrogations and that the lack of Miranda warnings rendered his statements inadmissible. However, the court found that admitting the statements was harmless error: the essential evidence was provided by other witnesses, and the statements were not crucial to the finding of delinquency. The Supreme Court of Wisconsin affirmed the decision of the court of appeals. View "State v. K. R. C." on Justia Law

In this case, a man was convicted by a jury of killing a woman, her unborn child, and her four-year-old daughter, as well as related offenses, and was sentenced to death for the child’s murder. The crimes occurred in an apartment where the man was present and had a relationship with the victims. The woman was engaged in drug dealing, and the man assisted her. On the afternoon of the murders, the man was alone with the victims shortly before the apartment was set on fire. The man was seen fleeing in the woman’s car, acted evasively with both family and police, changed his story multiple times, and was found with injuries and items linking him to the crime scene. At trial, DNA evidence and a jailhouse informant’s testimony were presented, among other circumstantial evidence.After his conviction and death sentence were affirmed on direct appeal by the Supreme Court of Pennsylvania, the man filed a timely petition under the Post Conviction Relief Act (PCRA) in the Bucks County Court of Common Pleas. He alleged, among other things, that the prosecution withheld impeachment evidence about key witnesses, failed to correct false testimony, and that his counsel was ineffective for failing to properly investigate and challenge the witnesses and DNA evidence, as well as for not presenting character evidence and additional mitigating evidence during sentencing. The PCRA court denied all relief, finding either no merit, no prejudice, or waiver as to the claims.On appeal, the Supreme Court of Pennsylvania reviewed the PCRA court’s denial. The Court agreed that, even if some deficiencies or omissions occurred, the circumstantial evidence against the man was overwhelming, and there was no reasonable probability that the result would have been different. The Court also found no error in the handling of mitigation evidence or in the recusal context. Ultimately, the Supreme Court of Pennsylvania affirmed the denial of post-conviction relief. View "Commonwealth v. Johnson" on Justia Law