Justia Criminal Law Opinion Summaries

The case concerns the conviction of Dion Bordeaux for first-degree murder following the shooting death of his girlfriend, Jeanette Jumping Eagle, in a Rapid City hotel room on January 1, 2020. Only Bordeaux and his brother Giovanni were present at the time of the shooting. Giovanni testified that Bordeaux and Jeanette had been arguing, and after hearing a gunshot while in the bathroom, he saw Bordeaux panicking. Bordeaux called 911, claiming Jeanette shot herself. Law enforcement found Jeanette deceased with a gunshot wound, her hand on a handgun, and evidence of blood transfer and gunshot residue. Bordeaux was arrested on an unrelated aggravated assault charge from September 2019, which later became central to the case.The Seventh Judicial Circuit Court, Pennington County, presided over the trial. The State sought to admit evidence of Bordeaux’s prior aggravated assault against his cousin, arguing it showed intent and a common scheme. The circuit court allowed this evidence, finding similarities between the two incidents. At trial, the State presented extensive forensic evidence and testimony, including details of the prior assault. Bordeaux’s defense argued that Jeanette’s death was a suicide, not homicide, and objected to the admission of the prior assault evidence, claiming it was prejudicial and not sufficiently similar to the charged offense.The Supreme Court of South Dakota reviewed the case. It held that the circuit court abused its discretion by admitting the prior aggravated assault evidence, finding insufficient similarity between the two incidents to justify its use for proving intent or a common scheme. The Court further determined that the admission of this evidence was prejudicial, as it was a significant part of the State’s case and likely influenced the jury’s verdict. The Supreme Court reversed Bordeaux’s conviction and remanded the case for a new trial. View "State v. Bordeaux" on Justia Law

The defendant was charged in Orleans County with multiple counts of larceny, stemming from allegations that he sold a vehicle entrusted to him for repairs and kept the proceeds. The Orleans County District Attorney sought to be disqualified due to a personal relationship with the alleged victim. The County Court granted the disqualification and appointed a special district attorney under County Law § 701(1)(a). However, the appointed special district attorney neither resided in nor had an office in Orleans County or any adjoining county, as required by the statute.After conviction, the defendant raised the issue of the special district attorney’s ineligibility for the first time on direct appeal. The Appellate Division, Fourth Department, found that the County Court exceeded its authority by appointing a special district attorney who did not meet the residency requirement and dismissed the indictment on that basis. The People were granted leave to appeal to the New York Court of Appeals.The New York Court of Appeals held that the residency requirement in County Law § 701(1)(a) is a non-waivable jurisdictional prerequisite. The court reasoned that strict adherence to the statute is necessary due to the separation of powers concerns involved when the judiciary appoints a substitute for an elected district attorney. The court distinguished this situation from cases involving assistant district attorneys appointed by a sitting district attorney, where residency requirements may be waivable. Because the County Court lacked authority to appoint a special district attorney who did not satisfy the statutory residency requirement, the indictment must be dismissed. The order of the Appellate Division was affirmed. View "People v Callara" on Justia Law

In July 2019, the defendant, his codefendant, and a third individual drove to a park, where both the defendant and codefendant fired guns from a vehicle into a crowd, resulting in the death of a victim. The shooting was allegedly in retaliation for a prior incident in which the codefendant had been shot. Both were charged under a single indictment with second-degree murder and four counts of criminal possession of a weapon, based on an acting-in-concert theory. At trial, a witness implicated both as shooters, and the defendant’s former girlfriend testified about his possession of guns and a statement he made about the killing. Surveillance footage and ballistics evidence supported the prosecution’s case, but the actual shooting was not captured on video.Before trial, the defendant moved for severance, arguing that the codefendant’s counsel intended to blame him for the shooting, which would be irreconcilable with his own defense. The Erie County Court denied the motion, finding the argument speculative and noting it would address any conflict if it arose during trial. During summation, the codefendant’s counsel argued that the evidence pointed to the defendant as one of the shooters. The defendant’s counsel renewed the severance motion, claiming the codefendant’s closing argument unfairly prejudiced the defendant. The court denied the renewed motion, emphasizing its instructions to the jury that attorneys’ arguments were not evidence and that the evidence should be considered separately for each defendant. The jury convicted the defendant on all counts.The Appellate Division affirmed, rejecting the claim that the trial court abused its discretion in denying severance. The New York Court of Appeals held that the trial court did not abuse its discretion, finding no undue prejudice from the codefendant’s summation and that the evidence was legally sufficient to support the verdict. The order of the Appellate Division was affirmed. View "People v Everson" on Justia Law

The case concerns an individual who was convicted by a jury of first-degree murder following the stabbing death of his fiancée. He was sentenced as a violent-felony habitual offender to life imprisonment. After his conviction was affirmed on direct appeal, he filed a timely postconviction petition under Arkansas Rule of Criminal Procedure 37.1, alleging ineffective assistance of counsel. His claims included that his attorney failed to move for dismissal based on a speedy-trial violation, did not object to double hearsay in a voicemail admitted at trial, failed to obtain a transcript of the voicemail, did not properly advise him about a plea offer, requested a mental evaluation without his consent, and failed to investigate or obtain certain cell-phone records.The Pulaski County Circuit Court, Seventh Division, reviewed the petition. The court found that the periods of delay in bringing the defendant to trial were excludable under Arkansas law, so a speedy-trial motion would not have succeeded. The court also determined there was no evidence that the State possessed a transcript of the voicemail or that the defense was denied access to it, and that the defense had thoroughly cross-examined the relevant witness. The court found the record contradicted the claim that the defendant was misadvised about the plea offer, as the terms were explained in detail on the record. The court further concluded that the request for a mental evaluation was not outside the bounds of reasonable professional assistance and that there was no evidence it affected the outcome of the trial. Some claims were not preserved for review because the circuit court did not rule on them.The Supreme Court of Arkansas affirmed the circuit court’s denial of postconviction relief. The court held that the petitioner failed to demonstrate deficient performance by counsel or resulting prejudice as required by Strickland v. Washington, and that the circuit court’s findings were not clearly erroneous. View "NEAL v. STATE OF ARKANSAS" on Justia Law

A woman was found dead in her home in Booneville, Arkansas, after police were alerted by her children. The investigation quickly focused on her former boyfriend, who had recently ended a relationship with her and was seen with blood on his clothing the night of the incident. Evidence included a confession, DNA linking him to the scene, and testimony that he entered the home through a window, confronted the victim, and strangled her after a physical altercation. The victim’s vehicle was also taken and later found abandoned.The Logan County Circuit Court held a jury trial in December 2022. The jury convicted the defendant of first-degree murder, residential burglary, and theft of property, and imposed a sentence enhancement for committing murder in the presence of a child. The defendant was sentenced to life imprisonment plus additional consecutive terms and fines. During trial, the court denied the defendant’s motions for directed verdict on all charges and the sentence enhancement, denied motions to suppress his statements to law enforcement, admitted certain autopsy photographs over objection, and excluded some mitigating evidence at sentencing due to late disclosure.On appeal, the Supreme Court of Arkansas reviewed four main issues: sufficiency of the evidence, admissibility of custodial statements, admission of autopsy photographs, and exclusion of mitigating evidence. The court held that there was substantial evidence to support the murder conviction and that the defendant’s sufficiency arguments regarding burglary, theft, and the sentence enhancement were not preserved for review. The court found no error in admitting the defendant’s statements or the autopsy photographs, and it upheld the exclusion of the late-disclosed mitigating evidence. The Supreme Court of Arkansas affirmed the convictions and sentences. View "WEATHERFORD v. STATE OF ARKANSAS" on Justia Law

Steven Robin was observed by police at an apartment complex parking lot, where officers saw him grab his waistband and duck behind a parked car. Officers believed he had deposited a firearm under the vehicle, and subsequent surveillance and body camera footage supported this account. Robin was arrested, and a firearm was recovered from under the car. DNA testing showed Robin’s DNA on the firearm but not on the magazine. At trial, Robin argued that someone else had placed the firearm there or that officers had planted it, and he presented evidence suggesting improper police handling of the firearm.The Superior Court of the District of Columbia presided over Robin’s trial. The judge instructed the jury that all exhibits except the firearm and ammunition would be available during deliberations, and that the firearm and ammunition could be examined only upon request, with a U.S. Marshal present for security. During deliberations, the jury requested to see the firearm, and the marshal brought it to the jury room. A juror asked if the magazine could be inserted into the gun, and the marshal either did so or allowed a juror to do so, but did not allow ammunition to be loaded. The jury conducted a demonstration with the firearm and found Robin guilty on all charges. After learning of these events, Robin moved for a new trial, arguing that the marshal’s interaction constituted impermissible ex parte communication and violated his constitutional rights. The trial judge denied the motion, finding the marshal’s actions ministerial and consistent with jury instructions.The District of Columbia Court of Appeals reviewed the case. The court held that Robin forfeited his claims by failing to object to the jury instructions regarding the marshal’s role. The court found no plain error in the marshal’s conduct, concluding that the marshal’s actions were ministerial and did not require judicial oversight or party input. The court affirmed Robin’s convictions. View "Robin v. United States" on Justia Law

Atravius Weeks was indicted for first-degree premeditated murder, first-degree domestic abuse murder, and second-degree intentional murder after he confessed to shooting and killing Cortney Henry in Dakota County, Minnesota. The incident occurred in June 2021, and Weeks was apprehended shortly after the crime. At trial, Weeks raised concerns about the racial composition of the jury panel, noting that Black individuals were underrepresented compared to the county’s population. He argued that the jury pool did not reflect a fair cross-section of the community, as required by the Constitution.The Dakota County District Court denied Weeks’s request for a new jury panel and, after a jury found him guilty on all counts, entered convictions for all three murder charges. Weeks’s direct appeal was stayed to allow him to file a postconviction petition, which included an expert affidavit suggesting that the use of voter registration and driver’s license lists for jury selection systematically underrepresents Black people. The district court summarily denied the postconviction petition, finding that Weeks failed to show systematic exclusion of Black jurors under the three-prong test from State v. Williams, and cited prior Minnesota cases holding that the jury selection process does not systematically exclude people of color.The Minnesota Supreme Court reviewed the case and held that the district court abused its discretion by summarily denying the postconviction petition. The Supreme Court found that, when the facts alleged are viewed in the light most favorable to Weeks, the record does not conclusively show he is entitled to no relief, and genuine issues of material fact remain regarding systematic exclusion. The Court also held that the district court violated Minnesota Statutes section 609.04 by entering convictions for both first-degree domestic abuse murder and second-degree intentional murder in addition to first-degree premeditated murder. The Supreme Court reversed and remanded for an evidentiary hearing and ordered the vacation of the lesser murder convictions. View "State of Minnesota vs. Weeks" on Justia Law

Víctor Miguel Duluc-Méndez was convicted for his role in a 2013 carjacking in Puerto Rico that resulted in the death of the vehicle’s driver. Duluc and a juvenile accomplice forcibly took a car, detained the driver, withdrew money from his account, and later, the juvenile fatally shot the driver. Duluc was apprehended shortly after and admitted to the carjacking, though he denied knowledge of the juvenile’s intent to kill. He pleaded guilty to the carjacking charge, and the United States District Court for the District of Puerto Rico sentenced him to 240 months in prison.After serving about ten years, Duluc moved for compassionate release under 18 U.S.C. § 3582(c)(1)(A), citing his mother’s deteriorating health and his siblings’ inability to care for her, supported by letters from his family. He also emphasized his substantial post-conviction rehabilitation, including completion of over a thousand hours of programming, leadership roles, and strong recommendations from prison staff and fellow inmates. The government opposed the motion, arguing that Duluc had not shown he was the only available caregiver and that rehabilitation alone was insufficient for compassionate release. The district court denied the motion in a brief order, finding Duluc’s family circumstances unconvincing and citing his criminal record, without addressing his rehabilitation arguments.The United States Court of Appeals for the First Circuit reviewed the denial. The court held that the district court abused its discretion by failing to consider Duluc’s argument that his rehabilitation, combined with his family circumstances, could constitute “extraordinary and compelling reasons” for release. The appellate court vacated the district court’s order and remanded the case for further proceedings, instructing the lower court to consider Duluc’s rehabilitation in its analysis. View "United States v. Duluc-Mendez" on Justia Law

The defendant purchased fifty-nine firearms over sixteen months, completing federal transaction records for each purchase and listing two Virginia addresses as his residence. However, he did not live at either address—one did not even exist. A grand jury indicted him on twenty-four counts of making false statements to a federal firearms licensee. The government had substantial evidence, including testimony from residents of the listed addresses and GPS data showing the defendant’s actual residence in Maryland. On the eve of trial, the defendant entered into a plea agreement, pleading guilty to one count in exchange for dismissal of the remaining counts and a sentencing recommendation for acceptance of responsibility.The United States District Court for the Eastern District of Virginia accepted the guilty plea after a colloquy that omitted several requirements of Federal Rule of Criminal Procedure 11, such as explicit discussion of the appeal waiver and the nonbinding nature of the Sentencing Guidelines. The defendant did not object at the time. Months later, after replacing his original counsel due to alleged ineffectiveness and disciplinary issues, the defendant moved to withdraw his plea, arguing it was not knowing and voluntary. The district court denied the motion and sentenced him to fourteen months’ imprisonment and two years of supervised release.The United States Court of Appeals for the Fourth Circuit reviewed the case, applying plain error review to the Rule 11 colloquy and abuse of discretion review to the denial of the motion to withdraw. The court held that, despite the procedural deficiencies, the defendant failed to show a reasonable probability that he would not have pleaded guilty absent the errors. The court also found no fair and just reason to permit withdrawal of the plea, given the evidence, the delay in seeking withdrawal, and the lack of prejudice to the defendant. The judgment of the district court was affirmed. View "United States v. Smith" on Justia Law

A man was accused of sexually abusing a minor, referred to as Jane Doe, based on allegations that surfaced in 2018 and 2019. Initially, the police received a referral from Child Protective Services after Doe made statements to a suicide hotline about being abused by her “father’s friend.” The case was closed when Doe refused to discuss the allegations. In 2019, after another suicide attempt, Doe identified the man by name during therapy, and this information was relayed to the police. Detective Thorsdottir conducted a forensic interview with Doe, who provided detailed accounts of abuse and identified the accused. The investigation included interviews with Doe’s parents and therapists, surveillance, and searches of the accused’s home, which yielded a handgun but no evidence of child pornography. The accused was arrested and indicted, but the charges were later dropped after new evidence suggested Doe had previously identified a different individual as her abuser.The accused filed a civil suit in Virginia state court, later removed to the United States District Court for the Eastern District of Virginia, alleging malicious prosecution under both state law and the Fourth Amendment. The district court dismissed the complaint under Rule 12(b)(6), finding that the plaintiff failed to plausibly allege a lack of probable cause for his arrest and prosecution, and that the detective was entitled to qualified immunity on the federal claim.On appeal, the United States Court of Appeals for the Fourth Circuit reviewed the dismissal de novo. The court held that the complaint and its exhibits did not plausibly allege that the detective acted with deliberate or reckless disregard for the truth, nor that she omitted material facts necessary to negate probable cause. The court concluded that probable cause existed based on Doe’s identification and corroborating evidence, and affirmed the district court’s dismissal of both the federal and state malicious prosecution claims. View "Moretti v. Thorsdottir" on Justia Law