Justia Criminal Law Opinion Summaries

In 1995, Michael Lambert was indicted for first-degree murder and later convicted of second-degree murder and committing a crime of violence while armed. He was sentenced to life imprisonment for the murder and an additional consecutive ten-year sentence for the crime of violence. His convictions were affirmed in 1997. After being denied parole multiple times, Lambert was granted parole in 2019, effective December 2020. However, in 2020, the Parole Board amended its decision, stating Lambert should have been paroled to his consecutive sentence, not the community.Lambert filed a pro se petition for a writ of habeas corpus in 2021, claiming unlawful detention due to the Rhode Island Department of Corrections' (RIDOC) method of calculating parole eligibility. The petition was treated as an application for postconviction relief, and the Superior Court appointed counsel for Lambert. Both parties filed cross-motions for summary judgment. The Superior Court granted Lambert's motion, ordering his immediate release on parole to the community.The Rhode Island Supreme Court reviewed the case. The Court affirmed the Superior Court's decision to aggregate Lambert's sentences for parole eligibility, referencing its recent decision in Neves v. State, which mandated aggregating sentences for parole purposes. However, the Court quashed the part of the Superior Court's judgment that ordered Lambert's immediate release to the community, stating that the Parole Board had only paroled him to his consecutive sentence, not the community. The case was remanded to the Superior Court for further proceedings consistent with this opinion. View "Lambert v. Salisbury" on Justia Law

Leslie Isben Rogge, aged 85, filed a motion for compassionate release in 2022, citing his age, deteriorating health, and need for specialized care as extraordinary and compelling reasons for his release. Rogge argued that his release would be consistent with applicable sentencing policy statements. The district court denied the motion without prejudice, stating that Rogge was not eligible to request relief himself under 18 U.S.C. § 3582(c)(1)(A), as amended by the First Step Act of 2018 (FSA).Rogge was convicted and sentenced in five separate armed bank robbery cases between 1984 and 1997. In July 2021, he filed a pro se motion for compassionate release, which was denied for failure to exhaust administrative remedies. He filed a second motion in July 2022, and the court appointed a Federal Public Defender, who filed an Emergency Motion for Reconsideration. The government opposed the motion, arguing that Rogge failed to show extraordinary and compelling circumstances and that his criminal history weighed against release. The district court concluded that Rogge was an "old law" inmate, ineligible to seek compassionate release under § 3582(c) until at least October 25, 2025, and denied the motion without prejudice.The United States Court of Appeals for the Eighth Circuit reviewed the case. The court held that defendants who committed their crimes before November 1, 1987, are not eligible to move for § 3582(c) compassionate release relief on their own behalf. The court affirmed the district court's decision, agreeing with other circuits that the FSA did not alter the exclusion of offenses predating November 1, 1987. Therefore, only the Bureau of Prisons may initiate a compassionate release request for Rogge, and it did not do so in this case. View "United States v. Rogge" on Justia Law

Kevon Spratt was charged with nine counts related to a series of robberies in western Iowa during the fall of 2022. The charges included four robberies or attempted robberies and associated firearm offenses, as well as unlawful possession of a firearm by a felon. Spratt moved to dismiss one count and to suppress evidence seized from his car, but the district court denied both motions. The jury acquitted him on two counts but convicted him on the remaining charges. Spratt appealed his convictions and sentence.The United States District Court for the Northern District of Iowa denied Spratt's motions to dismiss and suppress evidence. The jury found him guilty on seven counts, leading to a total sentence of 432 months and five years of supervised release. Spratt appealed these decisions, arguing errors in the denial of his motions, the admission of evidence, and the sufficiency of the evidence supporting his convictions.The United States Court of Appeals for the Eighth Circuit reviewed the case. The court held that the district court did not err in denying Spratt's motion to suppress, as the officers had probable cause based on collective knowledge and communication. The court also affirmed the denial of the motion to dismiss Count 8, ruling that attempted bank robbery under 18 U.S.C. § 2113(a) is a crime of violence. Additionally, the court found no abuse of discretion in admitting evidence of uncharged robberies under Rule 404(b) and determined that there was sufficient evidence to support Spratt's convictions. The court also upheld the district court's sentencing decisions, finding no procedural or substantive errors. The Eighth Circuit affirmed Spratt's convictions and sentence. View "United States v. Spratt" on Justia Law

In 1996, Roderick Rankin was sentenced to death for the murders of Zena Reynolds, Ernestine Halford, and Nathaniel Halford. Rankin filed a federal habeas petition, arguing that he was intellectually disabled at the time of the murders, his trial counsel was ineffective for not investigating and presenting evidence that his brother Rodney committed the murders, his trial counsel had conflicts of interest, the penalty-phase jury instructions violated Supreme Court precedents, and his trial counsel was ineffective for not objecting to these instructions. The district court denied habeas relief without an evidentiary hearing.The United States District Court for the Eastern District of Arkansas denied Rankin's habeas petition, finding that he had not exhausted all state court claims and stayed the proceedings to allow him to pursue relief in state court. Rankin's subsequent state court attempts were unsuccessful, and he returned to federal court with an amended habeas petition. The district court denied relief, noting that Rankin had not provided clear and convincing evidence to contradict the state court's determination that he was not intellectually disabled and that his other claims failed on the merits.The United States Court of Appeals for the Eighth Circuit reviewed the case and affirmed the district court's decision. The court held that the Arkansas Supreme Court's rejection of Rankin's intellectual disability claim was not based on an unreasonable determination of the facts. The court also found that Rankin's claims of ineffective assistance of counsel and jury instruction errors were procedurally defaulted and without merit. The court concluded that Rankin was not entitled to an evidentiary hearing on his claims. View "Rankin v. Payne" on Justia Law

The defendant, Rolando Joel De Leon De Paz, pleaded guilty to illegally reentering the United States in violation of 8 U.S.C. § 1326. De Leon had been removed from the U.S. five times previously, with his first removal in 2002 following a conviction for the sale and delivery of methamphetamine. Subsequent removals occurred in 2008, 2013, 2016, and 2022, each following separate convictions for illegal reentry. Despite escalating sentences for each conviction, De Leon reentered the U.S. again and was arrested in January 2023. He was indicted for illegal reentry and pleaded guilty after the district court denied his motion to dismiss the indictment on equal protection grounds.The United States District Court for the Western District of Wisconsin calculated a sentencing Guidelines range of 21 to 27 months but imposed an above-Guidelines sentence of 48 months. The court justified the sentence by emphasizing De Leon's repeated illegal reentries and the failure of previous escalating punishments to deter him. The court also noted De Leon's struggle with alcohol, which contributed to his criminal behavior, although this was not the main reason for the above-Guidelines sentence.The United States Court of Appeals for the Seventh Circuit reviewed the case and affirmed the district court's decision. The appellate court held that the district court acted within its discretion in imposing the 48-month sentence, finding that the justifications provided were consistent with the 18 U.S.C. § 3553(a) factors. The court noted that De Leon's repeated offenses and the ineffectiveness of prior sentences warranted the above-Guidelines sentence. Additionally, the appellate court rejected De Leon's argument that the district court improperly relied on his alcohol dependence and found no abuse of discretion in the sentencing decision. The court also affirmed the district court's denial of De Leon's motion to dismiss the indictment, citing recent precedent. View "United States v De Leon De Paz" on Justia Law

The plaintiff in error, Gregory Johnson, challenged his summary conviction of three counts of criminal contempt for repeatedly interrupting and directing racial slurs and other profanities at the court during his habeas corpus trial. He claimed that the trial court deprived him of his right to due process by not postponing the contempt proceeding and by not ordering it to be held before a different judge.The trial court, acting in the capacity of a trial court for the habeas proceeding, conducted the first day of the trial on April 4, 2023, and resumed on May 4, 2023. The plaintiff, appearing virtually, refused to comply with the court's instructions, used racial slurs, and swore at the court. The court warned the plaintiff multiple times before finding him in contempt. The court then appointed counsel for the plaintiff, allowed a private consultation, and provided an opportunity for both the plaintiff and his counsel to speak before sentencing.The Connecticut Supreme Court reviewed the case and found that the trial court's summary contempt proceeding substantially complied with the requirements of Practice Book § 1-16, which ensures fairness in the adjudication of summary criminal contempt. The court concluded that the plaintiff's behavior obstructed the orderly administration of justice, justifying the trial court's decision not to defer the proceeding under Practice Book § 1-17. The court also determined that the trial judge did not become personally embroiled in the controversy, as the judge maintained a calm demeanor and provided the plaintiff with multiple warnings and opportunities to explain his behavior.The court rejected the plaintiff's claim that his medical issues and alleged incompetency warranted deferral of the contempt proceeding. The trial court had observed the plaintiff's behavior and found him competent, and his counsel did not request a competency evaluation. The Connecticut Supreme Court dismissed the writ of error, upholding the trial court's findings and sentencing. View "Johnson v. Superior Court" on Justia Law

James Lynch was stopped in April 2022 under suspicion of driving under the influence and was subjected to five standardized field sobriety tests, including the horizontal gaze nystagmus (HGN) test. Lynch showed signs of impairment and was arrested and charged with DUI. In February 2023, Lynch moved to exclude the HGN test evidence, arguing it was unreliable without expert testimony. The Gallatin District Court agreed, requiring expert testimony for the HGN test and excluding it from evidence.The Commonwealth sought a writ of prohibition from the Gallatin Circuit Court to prevent the exclusion of the HGN test. The circuit court denied the writ, finding that the Commonwealth did not demonstrate great injustice or irreparable injury, as other evidence from the sobriety tests and officer observations could still be used. The Commonwealth appealed to the Court of Appeals, which reversed the circuit court's decision, holding that the exclusion of the HGN test constituted irreparable injury and that the test was admissible without expert testimony if properly administered by a trained officer.The Supreme Court of Kentucky reviewed the case and reversed the Court of Appeals' decision. The Supreme Court held that the Commonwealth failed to demonstrate great injustice or irreparable injury, as required for a writ of prohibition. The court emphasized that the remaining evidence was sufficient for prosecution and that the exclusion of the HGN test did not cause incalculable damage. The case was remanded to the Gallatin Circuit Court to reinstate the order denying the Commonwealth's petition for a writ of prohibition. View "Lynch v. Commonwealth" on Justia Law

Bobby Ray Osborne entered a conditional guilty plea to first-degree trafficking in a controlled substance and possession of drug paraphernalia, receiving a five-year prison sentence. The case arose when officers, acting on a tip about a stolen trailer, visited Osborne's property. Osborne consented to a search, during which he was found with a baggie containing a brown substance believed to be heroin and a large amount of cash. The officers did not find the stolen trailer but obtained a search warrant for Osborne's residence, yielding additional evidence.The Estill Circuit Court denied Osborne's motion to suppress the heroin and cash, finding that he voluntarily consented to the search. Osborne's subsequent motions to reconsider were also denied. He then entered a conditional guilty plea, reserving the right to appeal the suppression ruling. The Kentucky Court of Appeals affirmed the trial court's decision.The Supreme Court of Kentucky reviewed the case to clarify the distinction between a consensual encounter and an investigative detention under the Fourth Amendment. The court affirmed the lower courts' rulings, holding that Osborne voluntarily consented to the search. The court found that the officers' actions did not convert the consensual encounter into an investigative detention. The court also upheld the application of the plain view doctrine, determining that the incriminating nature of the baggie was immediately apparent once Osborne removed it from his pocket. The court concluded that the trial court's findings were supported by substantial evidence and that additional findings were unnecessary. View "Osborne v. Commonwealth" on Justia Law

Jeremy Mills was convicted in Allen Circuit Court for multiple offenses, including Unlawful Transaction with a Minor, Possession of Matter Portraying Sexual Performance by a Minor, and being a Persistent Felony Offender. Mills met the victim, A.C., through Facebook, where she initially claimed to be eighteen. They met in person, used drugs, and engaged in sexual activities, which Mills recorded. A.C. later revealed she was thirteen. Mills was sentenced to twenty years in prison.The Allen Circuit Court jury acquitted Mills of rape, strangulation, and kidnapping charges but convicted him on other counts. Mills argued that he never knew A.C. was underage, a claim contradicted by A.C. and Edward Troutt, a fellow inmate who testified that Mills confessed to knowing A.C.'s true age. Mills contended that Troutt fabricated the confession after accessing his case file.The Supreme Court of Kentucky reviewed the case, focusing on Mills' claim of a Brady violation due to the Commonwealth's failure to disclose a video interview with Troutt. The Court found that the video, which contained inconsistencies with Troutt's trial testimony, was favorable impeachment evidence. The trial court's failure to disclose this evidence and its refusal to recall Troutt for cross-examination constituted a Brady violation. The Supreme Court held that this violation undermined confidence in the verdict, warranting a reversal of Mills' convictions and a remand for further proceedings. View "Mills v. Commonwealth" on Justia Law

In April 2012, Glenn A. Peeler, Jr. was convicted of two counts of complicity to commit robbery and being a persistent felony offender, resulting in a 22-year prison sentence. Peeler's convictions and sentence were affirmed on direct appeal. In August 2013, Peeler filed a pro se motion under Kentucky Rule of Criminal Procedure (RCr) 11.42, alleging ineffective assistance of counsel. The motion lacked proper verification as required by RCr 11.42(2). The trial court denied the motion on its merits in October 2013 without addressing the verification issue. Peeler's appeal of this ruling was dismissed as untimely by the Court of Appeals.In August 2016, Peeler filed a second RCr 11.42 motion, which was denied as successive and procedurally barred. The Court of Appeals affirmed this denial in October 2018. In December 2019, Peeler filed a motion under Kentucky Rule of Civil Procedure (CR) 60.02(e), arguing that the trial court lacked jurisdiction over his unverified 2013 motion. The trial court denied this motion, and the Court of Appeals affirmed, noting Peeler had waived any jurisdictional challenge by not raising it earlier.Peeler then petitioned the Court of Appeals for a writ of mandamus, seeking a nunc pro tunc order to dismiss his 2013 motion, notify him of its deficiency, allow correction, and appoint counsel. The Court of Appeals denied the petition, stating Peeler had an adequate remedy by appeal and had waived the jurisdictional issue.The Supreme Court of Kentucky reviewed the case and affirmed the Court of Appeals' decision. The Court held that Peeler had waived any jurisdictional issues by not raising them timely and had an adequate remedy by appeal. The Court also found that the trial court had general subject-matter jurisdiction over Peeler's RCr 11.42 motion and that substantial compliance with procedural requirements was sufficient. Thus, Peeler was not entitled to a writ of mandamus. View "Peeler v. Simcoe" on Justia Law