Justia Criminal Law Opinion Summaries

James Dixon was convicted in 2008 of first-degree murder and two counts of rape. The jury found true special-circumstance allegations that the murder was committed during a robbery and kidnapping, and Dixon was sentenced to death. Additionally, the court imposed and stayed execution of two consecutive terms of 25 years to life for the rape convictions, a one-year firearm enhancement, and four one-year prior prison term enhancements under Penal Code section 667.5, former subdivision (b).The Department of Corrections and Rehabilitation informed the Superior Court of Los Angeles County in 2023 that Dixon was eligible for recall and resentencing under section 1172.75. The superior court, without holding a hearing, permanently stayed execution of the prior prison term enhancements but ruled Dixon was not eligible for resentencing because the trial court had stayed execution of his enhancements. Dixon appealed, arguing he was entitled to a full resentencing.The California Court of Appeal, Second Appellate District, Division Seven, reviewed the case. The court concluded that the superior court had jurisdiction to resentence Dixon on the noncapital portions of his sentence, despite his pending automatic appeal in the Supreme Court. The court held that section 1172.75 applies to all enhancements imposed under section 667.5, former subdivision (b), whether executed or stayed. Therefore, the superior court should have stricken the prior prison term enhancements and conducted a resentencing hearing on the non-death portions of Dixon’s sentence.The Court of Appeal reversed the superior court's order and directed it to vacate its previous order, strike Dixon’s prior prison term enhancements, and resentence him on the rape convictions and the firearm enhancement in accordance with section 1172.75. The superior court was also instructed to prepare a new abstract of judgment and send it to the Department. View "P. v. Dixon" on Justia Law

Duane Berry was indicted in 2015 for planting a fake bomb outside a building in Detroit. The district court in Michigan found him mentally incompetent to stand trial and committed him to the custody of the Attorney General under 18 U.S.C. § 4241 for a competency evaluation. After determining that his competency could not be restored, the court dismissed the charges against him in December 2019. Concerned about his potential danger to the public, the court ordered a psychological evaluation under 18 U.S.C. § 4246.The government faced delays due to a backlog at the evaluation facility and the COVID-19 pandemic. Berry was eventually evaluated, and the facility's director certified that his release would pose a substantial risk. The United States District Court for the Eastern District of North Carolina held a hearing and found by clear and convincing evidence that Berry met the criteria for commitment under § 4246, as he was still in custody under § 4241 when the certification was filed.Berry appealed, arguing that he did not fall into any of the categories eligible for commitment under § 4246 and that the delay in filing the certification was unreasonable. The United States Court of Appeals for the Fourth Circuit reviewed the case and concluded that Berry was in lawful custody under § 4241 at the time of the certification. The court found the delay reasonable given the administrative challenges and the pandemic. The Fourth Circuit affirmed the district court's decision to commit Berry under § 4246, holding that the statutory provisions were followed correctly and that Berry's continued custody was lawful. View "United States v. Berry" on Justia Law

The defendant was convicted of felony murder and attempted robbery in the first degree, among other charges, following an incident where another individual, Christian, shot and killed the victim, Rodney, during a scuffle that ensued after the defendant attempted to rob Rivera. The defendant appealed, arguing that the state needed to prove that Christian was an accessory to the attempted robbery to secure a felony murder conviction.The trial court had instructed the jury on the felony murder statute, which does not require the state to prove that a participant in the crime was an accessory. The defendant was found guilty of felony murder, attempted robbery, and firearm offenses, but not guilty of murder as an accessory. The trial court vacated the manslaughter conviction on double jeopardy grounds and sentenced the defendant to forty years in prison.The Connecticut Supreme Court reviewed the case and held that the felony murder statute does not require the state to establish that a participant who caused the death was an accessory to the predicate felony. The court found sufficient evidence to support the conviction, noting that Christian's actions were in furtherance of the attempted robbery and that the killing occurred during the continuous sequence of events surrounding the attempted robbery.The court also rejected the defendant's claim of instructional error, as the trial court's instructions were legally proper and did not need to include a requirement for proving accessorial liability. Additionally, the court found that the defendant had waived his confrontation clause claim by not objecting to the admission of Rivera's video-recorded interviews at trial.Finally, the court declined to overrule its precedent in State v. Newsome, which allows a reliable out-of-court statement to serve as the sole evidentiary basis for a conviction. The court concluded that Rivera's statements were reliable and corroborated by other evidence, thus sufficient to establish the defendant's intent to commit attempted robbery.The judgment of the trial court was affirmed. View "State v. Hinton" on Justia Law

Deshawn Lynn Randolph was charged with two counts of soliciting for child prostitution under Colorado law. The charges stemmed from interactions with an undercover investigator posing as a minor on a social networking platform. Randolph offered to arrange sex work for the investigator, who had claimed to be underage. At trial, Randolph argued that he did not intend to arrange sex work but was merely boasting to delay any action until the investigator turned eighteen.The district court instructed the jury that the applicable mental state for the charges was "knowingly," rejecting Randolph's proposed instruction that would have required proof of "intentionally." The jury found Randolph guilty, and he was sentenced to two concurrent nine-year terms. Randolph appealed, arguing that the jury instructions were incorrect. The Colorado Court of Appeals affirmed the convictions, holding that "knowingly" was the correct mental state.The Supreme Court of Colorado reviewed the case to resolve the appropriate mental state for the crime of soliciting for child prostitution. The court held that the culpable mental state for the crime under subsections (1)(a) and (1)(b) of the statute is "knowingly," aligning with the mental state explicitly designated in subsection (1)(c). The court affirmed the lower court's judgment, concluding that the district court did not err in its jury instructions. View "Randolph v. People" on Justia Law

In 2008, Kelly James Schnorenberg formed KJS Marketing, Inc. to secure funding and recruit agents for insurance companies. Between 2009 and 2015, KJS solicited over $15 million from approximately 250 investors, promising a 12% annual return. Schnorenberg failed to disclose to investors his past legal and financial troubles, including a lawsuit by the Colorado Division of Securities, a permanent injunction from selling securities in Colorado, a bankruptcy filing, and unpaid civil judgments.Schnorenberg was charged with twenty-five counts of securities fraud under section 11-51-501, with twenty-four counts based on materially false statements or omissions and one count based on a fraudulent course of business. He planned to defend himself by arguing that he acted in good faith reliance on the advice of his securities lawyer, Hank Schlueter. However, the trial court denied his motions for a continuance to secure Schlueter's testimony and excluded Schnorenberg's testimony about the specific advice he received, ruling it as hearsay.The Colorado Court of Appeals vacated seven of Schnorenberg's convictions as time-barred, reversed the remaining convictions, and remanded the case for further proceedings. The court concluded that the trial court erred in excluding Schnorenberg's testimony about his lawyer's advice and in not instructing the jury that good faith reliance on the advice of counsel could negate the mens rea element of the securities fraud charges.The Supreme Court of Colorado reviewed the case and held that the mens rea of "willfully," synonymous with "knowingly," applies to each element of securities fraud under subsections 11-51-501(1)(b) and (c). The court concluded that Schnorenberg's testimony about his lawyer's advice was relevant to whether he had the requisite mens rea and that the trial court erred in excluding this testimony. The court affirmed the judgment of the Court of Appeals and remanded the case for a new trial. View "People v. Schnorenberg" on Justia Law

Evelio Santana pleaded guilty to unlawful possession of a firearm as a convicted felon. His sentence was enhanced under the Armed Career Criminal Act (ACCA) after the district judge found by a preponderance of the evidence that Santana had three prior convictions for violent felonies committed on different occasions. Santana appealed, arguing that the determination should have been made by a jury beyond a reasonable doubt, as required by a recent Supreme Court decision in Erlinger v. United States.The United States District Court for the Southern District of Indiana initially handled Santana's case. The district judge determined that Santana's prior convictions were committed on different occasions and sentenced him to the mandatory minimum of fifteen years in prison under the ACCA. Santana's lawyer had agreed with the judge's authority to make this determination based on then-current Seventh Circuit precedent. The government objected, arguing that a jury should make the determination, but the judge overruled the objection.The United States Court of Appeals for the Seventh Circuit reviewed the case. The court found that an error occurred because the judge, not a jury, made the different-occasions determination by a preponderance of the evidence, contrary to the Supreme Court's ruling in Erlinger. The error was plain and affected Santana's substantial rights by increasing his sentence. The court concluded that the error undermined the fairness and integrity of the proceedings, as a reasonable jury might have found reasonable doubt about whether the prior felonies were committed on different occasions. Consequently, the Seventh Circuit vacated Santana's sentence and remanded the case for resentencing consistent with the Supreme Court's decision in Erlinger. View "United States v Santana" on Justia Law

Kenneth Alfonso Gallegos and three friends attempted to obtain vaping products from a high school classmate, L.C. During the encounter, a struggle ensued, and one of Gallegos's friends fatally shot L.C. Gallegos was charged with felony murder, with predicate felonies of aggravated robbery, attempted robbery, and conspiracy to commit aggravated robbery. At trial, Gallegos denied planning to rob L.C. or knowing about the gun. He requested a jury instruction on the affirmative defense to felony murder, which the trial court denied, deeming it incompatible with his outright denial of involvement in the crime.The jury found Gallegos guilty, and he appealed. The Colorado Court of Appeals reversed his felony murder conviction, holding that defendants may both deny the predicate felony and raise the affirmative defense to felony murder. The court found that the trial court erred by not giving Gallegos's requested instruction.The Supreme Court of Colorado reviewed the case and held that a defendant need not admit the predicate felony to raise the affirmative defense to felony murder. The court affirmed the judgment of the court of appeals, concluding that the plain language of the affirmative defense statute does not require an admission of the underlying felony. The court emphasized that the affirmative defense to felony murder can be raised even if the defendant denies committing the predicate felony, as long as there is some credible evidence supporting the defense's conditions. View "People v. Gallegos" on Justia Law

Isaiah Ismael Rios was charged with multiple counts, including first-degree murder, related to a series of crimes over eighteen days. His trial, initially set for July 2020, was delayed due to the COVID-19 pandemic. The trial court, following public health guidelines, excluded all spectators from the physical courtroom, providing virtual access instead. Rios objected, arguing this violated his Sixth Amendment right to a public trial. The trial proceeded with these restrictions, and Rios was convicted.The Colorado Court of Appeals reviewed the case and determined that the exclusion of the public from the courtroom constituted a nontrivial partial closure. However, it concluded that Rios's right to a public trial was not violated because the closure was justified under the Supreme Court's standard in Waller v. Georgia. The court found that the closure was warranted due to the public health crisis, was no broader than necessary, and that reasonable alternatives were considered.The Supreme Court of Colorado reviewed the case and held that virtual access alone does not satisfy the Sixth Amendment right to a public trial. The court determined that a courtroom closure occurred but concluded that the closure did not violate Rios's right to a public trial. The court found that the closure was justified under the Waller factors due to the public health concerns related to COVID-19. Therefore, the Supreme Court of Colorado affirmed the judgment of the court of appeals. View "Rios v. People" on Justia Law

The case involves Robert Keith Ray, who was charged with multiple offenses related to the murders of Javad Marshall-Fields and Vivian Wolfe in a drive-by shooting. Marshall-Fields was set to testify against Ray in a separate shooting incident at Lowry Park, where Ray and his associate, Sir Mario Owens, were involved. Ray was convicted of nearly all charges related to the Dayton Street shooting and was initially sentenced to death. However, after Colorado abolished the death penalty, the Governor commuted Ray's sentence to life without the possibility of parole (LWOP).The Arapahoe County District Court entered the judgment of conviction and sentenced Ray to death, which was later commuted to LWOP. Ray appealed his convictions and sentence directly to the Colorado Supreme Court, challenging several evidentiary rulings, prosecutorial misconduct, and the constitutionality of his LWOP sentence. He also alleged juror misconduct and sought to subpoena jurors to investigate these claims.The Colorado Supreme Court reviewed Ray's appeal and found that while the district court made some errors in admitting certain evidence and that some of the prosecution's comments were improper, none of these errors warranted reversal. The court concluded that the district court properly denied inquiry into alleged juror misconduct under CRE 606(b) and upheld the constitutionality of Ray's LWOP sentence. The court affirmed the judgment of conviction and the commuted sentence. View "People v. Ray" on Justia Law

Cody Byron Teerlink was convicted of making a false statement during the acquisition of a firearm. He had previously pleaded guilty to a third-degree felony for driving under the influence in Utah and completed his probation successfully. Despite being eligible for a reduction of his felony to a misdemeanor under Utah law, he did not apply for it. In 2021, Teerlink attempted to purchase firearms on three occasions, falsely stating on ATF Form 4473 that he had not been convicted of a felony. He was able to purchase a rifle once due to a system glitch but was denied on the other two attempts.The United States District Court for the District of Utah directed the parties to agree on jury instructions. The parties jointly submitted an instruction defining "proof beyond a reasonable doubt," which included language criticized by the Tenth Circuit and the Supreme Court. The jury convicted Teerlink on one count of making a false statement during the acquisition of a firearm and acquitted him on the other counts. He was sentenced to eight months' imprisonment.The United States Court of Appeals for the Tenth Circuit reviewed the case. Teerlink argued that the jury instruction lowered the government's burden of proof, violating his Fifth Amendment rights. However, the court held that Teerlink invited any alleged error by jointly submitting the instruction and failing to object at trial. The court emphasized that parties cannot propose jury instructions and later challenge them on appeal. The court also rejected Teerlink's argument that a footnote in the jury instructions preserved his right to plain-error review, stating that such a footnote cannot immunize a party from the invited-error doctrine. The Tenth Circuit affirmed the district court's decision. View "United States v. Teerlink" on Justia Law