Justia Criminal Law Opinion Summaries

The defendant was convicted after pleading no contest to voluntary manslaughter and two counts of willful, deliberate, and premeditated attempted murder. The underlying events involved a shooting at a party where gang rivalry escalated into violence. During the investigation, law enforcement conducted a Perkins operation by placing a confidential informant in a cell with the defendant's codefendant, who made statements implicating both himself and the defendant in the shooting. These statements, along with cell phone evidence, linked the defendant to the scene and the crime.The defendant later petitioned for resentencing under Penal Code section 1172.6, enacted following Senate Bill No. 1437, which reformed the law regarding murder liability and allowed certain individuals convicted under now-invalid theories to seek resentencing. The Superior Court of Los Angeles County held an evidentiary hearing, relying primarily on testimony from the preliminary hearing, including an officer’s recounting of the codefendant’s incriminating statements. The court found that these statements were admissible as declarations against penal interest and denied the resentencing petition.On appeal, the California Court of Appeal, Second Appellate District, Division Eight, reviewed whether the trial court properly admitted the codefendant’s statements pursuant to the hearsay exception for declarations against interest under Evidence Code section 1230, and whether there was sufficient evidence to deny relief. The appellate court held that the trial court correctly admitted the preliminary hearing testimony as declarations against interest, as they subjected the codefendant to criminal liability and were trustworthy. The court also found any error in admitting a recording of the Perkins operation was harmless because other evidence was substantial. The order denying resentencing was affirmed. View "People v. Pineda" on Justia Law

The case concerns a defendant who, in 2017, was charged with multiple felonies, including attempted murder, after stabbing his romantic partner 17 times while she was hospitalized. He pleaded guilty to willfully inflicting traumatic injury on a partner, having a prior conviction for the same offense, and the prosecution dismissed the other counts. The sentencing judge imposed the upper term of five years for this conviction, doubled it due to a prior strike, and added enhancements for prior convictions and weapon use, resulting in a 17-year prison sentence.Following legislative changes in 2021 that invalidated enhancements for prior prison terms and required full resentencing in affected cases, the defendant sought resentencing under Penal Code section 1172.75. During resentencing in the Superior Court of Los Angeles County, the court struck the one-year enhancements for the prior prison term and weapon use but otherwise maintained the upper-term sentence for the underlying offense. The court justified the upper term based on the admitted prior conviction and weapon use, which were acknowledged in the defendant’s original plea.On appeal, the defendant argued that the resentencing court exceeded its authority by reimposing the upper term without a jury finding, or his stipulation to, the aggravating factors, citing Sixth Amendment concerns. The California Court of Appeal, Second Appellate District, Division Eight, considered whether Penal Code section 1172.75 required new factfinding for upper-term sentences at resentencing when the upper term had already been imposed in compliance with constitutional requirements.The Court of Appeal held that when a defendant was originally sentenced to the upper term, the resentencing court may reimpose that term without requiring a jury finding or a stipulation to the aggravating factors. The court concluded this result is consistent with the statutory language and constitutional requirements. The judgment was affirmed. View "People v. Moss" on Justia Law

A man attended an office holiday party, drank heavily over several hours, and later refused a co-worker’s offer of a ride home. Despite visible signs of impairment, such as struggling with a parking garage payment kiosk and breaking a mechanical arm to exit the garage, he chose to drive his own car. On the highway, he drove erratically and at excessive speeds, nearly sideswiping other vehicles and missing his intended exit multiple times. Ultimately, while driving at 113 to 115 miles per hour with a blood alcohol content almost twice the legal limit, he looked away from the road to search for his phone, failed to brake in time, and crashed into a car, causing it to burst into flames. Two occupants died from burns, and two others suffered serious injuries.The Bucks County Court of Common Pleas held a jury trial in which he was convicted of multiple offenses, including two counts each of third-degree murder and aggravated assault. The court imposed a sentence of 19½ to 39 years in prison. The Pennsylvania Superior Court, sitting en banc, affirmed the conviction and sentence. The majority concluded that the evidence was sufficient to establish malice because the defendant’s conduct showed a conscious disregard for an unjustified and extremely high risk that his actions might cause death or serious bodily injury. The dissent argued for a more stringent, DUI-specific malice standard.The Supreme Court of Pennsylvania reviewed the case to clarify the standard for malice in DUI cases. The Court held that there is a single, uniform standard for malice: malice is present if the defendant consciously disregarded an unjustified and extremely high risk that his actions might cause death or serious bodily injury, regardless of whether the conduct involved DUI or another act. The Court affirmed the Superior Court’s order upholding the convictions and sentence. View "Commonwealth v. Peters" on Justia Law

A man was convicted by a jury in Arizona of kidnapping, sexual assault, and murder in 1996, and received a death sentence from a judge. After his conviction was affirmed on direct appeal by the Arizona Supreme Court, he sought postconviction relief in state court, but his counsel failed to investigate or present any claim of ineffective assistance of counsel (IAC) at the sentencing phase. The first postconviction relief (PCR) attorney never met with him and was unaware of the need to investigate sentencing issues. No mitigating evidence or penalty-phase IAC claim was presented to the state courts at that time.The state trial court dismissed his initial PCR petition, and the Arizona Supreme Court denied further review. He then filed a federal habeas petition, raising, for the first time, claims that his trial and PCR counsel were ineffective at sentencing and arguing that he was ineligible for execution due to intellectual disability. The United States District Court for the District of Arizona found his claims procedurally defaulted because they had not been presented in state court and Arizona law generally bars such successive claims. The district court also found that ineffective assistance of PCR counsel did not excuse the default. After the Supreme Court’s decision in Martinez v. Ryan, which allowed ineffective PCR counsel as cause to excuse certain procedural defaults, the case was remanded for further consideration. New mitigating evidence was presented, but subsequent Supreme Court jurisprudence (Shinn v. Ramirez) prevented the federal court from considering evidence not first presented to the state court.The United States Court of Appeals for the Ninth Circuit held that it was not clear whether Arizona courts would find the penalty-phase IAC claim procedurally barred and, applying Rhines v. Weber, granted a stay and abeyance. This allows the petitioner to return to state court to present his unexhausted IAC claim, as the Rhines criteria were satisfied: good cause existed, the claim was potentially meritorious, and there was no intentional delay. The court remanded with instructions to stay federal proceedings pending state court exhaustion of the claim. View "DOERR V. SHINN" on Justia Law

Two men attacked a couple as they entered their condominium, robbing them and sexually assaulting the woman. During the incident, the male victim was fatally shot. Decades later, DNA evidence linked one of the assailants, Morris, to the crime. In 2013, Morris was convicted by a jury of first degree murder, with special circumstances for rape, robbery, and murder for financial gain. The jury found that Morris acted with intent to kill, and the trial court sentenced him to life without parole. The conviction was affirmed on appeal.After changes to California’s felony-murder rule under Senate Bill 1437, Morris filed a petition for resentencing under Penal Code section 1172.6, arguing he was ineligible for murder liability as a nonkiller under the amended law. The Superior Court summarily denied the petition at the prima facie stage, reasoning that the jury’s findings established Morris’s intent to kill, making him ineligible for relief. The California Court of Appeal, in a split decision, affirmed the denial. The majority held that, under the amended law, it was sufficient that Morris acted with intent to kill and aided the underlying felony, even if he was not the actual killer. The dissenting judge argued that the law requires a nonkiller to have aided the actual killer in the lethal act itself, not just in the underlying felony.The Supreme Court of California reviewed the case to resolve a conflict among appellate courts regarding the actus reus requirement for nonkiller aiders and abettors under section 189, subdivision (e)(2). The Supreme Court held that, for a nonkiller to be liable for felony murder under this provision, the prosecution must prove that the nonkiller, with intent to kill, aided or abetted the actual killer in the commission of the lethal act itself—not merely in the commission of the underlying felony. The Court reversed the Court of Appeal and remanded for further proceedings. View "P. v. Morris" on Justia Law

In 2000, Briley Piper and two others committed the murder of Chester Allan Poage in South Dakota, resulting in Piper being charged with multiple offenses, including first-degree felony murder. Prior to trial, Piper pled guilty to five crimes and was sentenced to death by the state circuit court. Over the years, Piper’s case returned to the South Dakota Supreme Court several times, both on direct appeal and in habeas proceedings. The South Dakota Supreme Court initially affirmed his conviction and sentence, later vacated the death sentence due to an invalid jury waiver, and remanded for jury resentencing. The jury again imposed a death sentence, which was affirmed. Piper then filed successive state habeas applications, challenging the validity of his guilty pleas and the effectiveness of his counsel, all of which were ultimately denied.After exhausting state remedies, Piper filed a federal habeas corpus petition in the United States District Court for the District of South Dakota, advancing thirteen claims; the district court denied relief on all, granting a certificate of appealability for several. The United States Court of Appeals for the Eighth Circuit expanded the certificate to include six claims. The court reviewed issues including the constitutionality of AEDPA deference after Loper Bright Enterprises v. Raimondo, South Dakota’s application of res judicata to preclude Piper’s challenge to his guilty pleas, the denial of an evidentiary hearing regarding alleged ineffective assistance of counsel, the adequacy of impeachment of a key witness, alleged failures to rebut a prosecution assertion about a defense witness, and cumulative prejudice.The Eighth Circuit held that AEDPA’s deference requirement remains constitutional and applicable after Loper Bright. It found Piper’s challenge to his guilty pleas procedurally defaulted under South Dakota’s consistently applied res judicata rules. The court concluded the district court did not err in denying an evidentiary hearing, found no prejudice in counsel’s performance regarding impeachment or rebuttal evidence, and reaffirmed that cumulative error does not warrant habeas relief in this circuit. The court affirmed the district court’s denial of habeas relief. View "Piper v. A.G." on Justia Law

In this case, the defendant was convicted by a jury in 1972 of two counts of first-degree murder and one count of armed robbery, stemming from a fatal robbery at a supermarket in Dorchester, Boston. During the robbery, two security employees were shot and killed, and eyewitnesses identified the defendant as one of the perpetrators. Significant physical evidence linking the defendant to the crime was found shortly afterward, including stolen cash, murder weapons (one of which the defendant admitted owning), and the defendant himself at his sister’s apartment, where a wounded co-defendant was also present. The defense argued misidentification and denied participation in the crimes.Following the convictions, the defendant’s appeal was never perfected due to failures by both trial and appellate counsel. Later, the defendant escaped from custody in 1980, which resulted in the dismissal of his motion for a new trial. He was returned to custody in 1988 but did not promptly pursue appellate review. Decades later, the Supreme Judicial Court of Massachusetts permitted him to seek a motion for a new trial, treating any appeal from its denial as the functional equivalent of a direct appeal.The Supreme Judicial Court of Massachusetts reviewed the defendant’s claims of trial error under the law as it stood in 1980, allowing retroactive application of post-1980 legal developments only if the defendant was not at fault for the delay. The court found no reversible error in the jury instructions, the use of the prisoner's dock, the admission of certain evidence, or the prosecutor’s closing argument. The court also found no prejudice from alleged nondisclosure of an agreement with a prosecution witness. The court affirmed the denial of the motion for a new trial and concluded that no relief was warranted under its plenary review authority. View "Commonwealth v. White" on Justia Law

Rodriquez Lamont Hamilton was convicted of felony murder, aggravated assault, and related firearm offenses after the fatal shooting of Jamarius Cowart and the non-fatal shooting of Allysia Bryant in Brunswick, Georgia. The evidence showed that Hamilton and Bryant, who shared a tumultuous past relationship, were living together with their children, but Bryant was dating Cowart at the time of the incident. On the night of November 2, 2022, Hamilton encountered Bryant and Cowart in their car, fired several shots at them, fatally wounding Cowart and injuring Bryant. Surveillance footage, eyewitnesses, and ballistic evidence linked Hamilton to the scene. Hamilton did not testify, and his defense questioned the reliability of Bryant’s identification and the completeness of the police investigation.Hamilton was indicted in Glynn County Superior Court for malice murder, felony murder, aggravated assault, and firearm possession during the commission of a felony. At trial, the jury acquitted him of malice murder but found him guilty on the other counts. He was sentenced to life without parole for felony murder and consecutive sentences for the remaining charges. Hamilton’s motion for a new trial was denied by the trial court, and he timely appealed.The Supreme Court of Georgia reviewed Hamilton’s claims that the trial court abused its discretion in denying mistrials resulting from a courtroom outburst and a police officer’s remark about his post-arrest silence, and in admitting evidence of prior difficulties between Hamilton and the victims. The court held that the trial court did not abuse its discretion regarding the mistrial requests and that any error in admitting some of the prior acts evidence was harmless. The court also rejected his cumulative error argument. The Supreme Court of Georgia affirmed Hamilton’s convictions. View "HAMILTON v. STATE" on Justia Law

Police officers discovered the appellant in possession of an unregistered semiautomatic firearm that was equipped with a magazine capable of holding thirty rounds. He was indicted for possessing a “large capacity ammunition feeding device,” possession of an unregistered firearm, carrying a pistol without a license, and unlawful possession of ammunition. The facts were largely undisputed; the firearm had a thirty-round magazine, was unregistered, and the appellant did not have a license to carry it.The Superior Court of the District of Columbia, presided over by a judge, denied the appellant’s motion to suppress evidence and his motion to dismiss, which had argued that the District’s firearm statutes violated the Second Amendment, focusing in part on the magazine capacity ban and the District’s registration and licensure schemes. The court reasoned that Supreme Court precedent, particularly New York State Rifle & Pistol Association v. Bruen, did not invalidate the District’s gun laws. The case proceeded to a bench trial on stipulated facts, and the appellant was convicted on all four counts.On appeal, the District of Columbia Court of Appeals reviewed the case. The United States conceded the ban’s unconstitutionality, while the District continued to defend it. The court held that magazines capable of holding more than ten rounds are arms in common and ubiquitous use by law-abiding citizens, and there is no historical tradition of banning such arms. The court concluded that the District’s ban on these magazines violated the Second Amendment. It reversed all of the appellant’s convictions, holding that the unconstitutionality of the magazine ban also invalidated his convictions for possession of an unregistered firearm, carrying a pistol without a license, and unlawful possession of ammunition, since those charges depended on the magazine prohibition. View "Benson v. United States" on Justia Law

The case concerns an incident in which the defendant unlawfully entered a West Hartford residence where several individuals were present, including his ex-girlfriend and her new partner. The defendant shot the new partner in the face and threatened others before fleeing. He was apprehended shortly afterward, and gunshot residue was found on his hand. The prosecution charged him with multiple counts, including first-degree assault with a firearm, home invasion, criminal possession of a firearm, threatening, and risk of injury to a child. At trial, the defense argued that a third party was responsible for the shooting, but the jury found the defendant guilty on all counts.Prior to this appeal, the Superior Court in the judicial district of Hartford presided over the trial and delivered the conviction. The operative information charged the defendant with home invasion under the general statute but described conduct that aligned with committing a felony (assault) during the invasion. However, the trial court instructed the jury using a different statutory subdivision, focusing on whether the defendant was armed with a deadly weapon during the home invasion. The defense did not object to the home invasion instruction at trial.On direct appeal to the Connecticut Supreme Court, the defendant argued that his Sixth Amendment right to notice was violated because the jury was instructed on a statutory theory not specifically charged, and that his convictions for both home invasion and first-degree assault violated the double jeopardy clause. The Connecticut Supreme Court held that there was no plain error in the jury instruction, finding the information provided adequate notice for conviction under either statutory subdivision, and that the defense was not prejudiced. The Court further held that the convictions did not violate double jeopardy, as each offense required proof of an element the other did not. The judgment of conviction was affirmed. View "State v. Christon M." on Justia Law