Justia Criminal Law Opinion Summaries

The case involves a criminal trial where the defendant was charged with second-degree sexual abuse and third-degree rape. Before his arrest, law enforcement conducted a phone interview with the defendant, during which he made no admissions. The state did not present evidence of this phone call during its case-in-chief, and the prosecutor assumed that this precluded defense counsel from mentioning the call during cross-examination. During closing arguments, defense counsel referred to the lack of evidence about any interview or admissions by the defendant, leading to multiple objections from the state, which the trial court sustained.The trial court allowed defense counsel to argue that there was no evidence of admissions by the defendant but prohibited statements suggesting that no interview had occurred. The jury found the defendant guilty on both charges. On appeal, the defendant argued that the trial court erred in sustaining the state's objections and that the court's sua sponte instruction to the jury not to speculate about whether an interview had occurred was improper.The Court of Appeals affirmed the trial court's decision, concluding that the trial court had not abused its discretion in sustaining the objections and that the defendant had not preserved his argument regarding the jury instruction. The Oregon Supreme Court reviewed the case and concluded that the trial court did not err in sustaining the state's objection to the first statement by defense counsel but did err in sustaining the objection to the fourth statement. However, the court found that the error was harmless. The court also agreed that the defendant had not preserved his argument regarding the jury instruction and declined to reach the merits of that issue. The decision of the Court of Appeals and the judgment of the circuit court were affirmed. View "State v. Burton" on Justia Law

The case involves a criminal matter where the defendant was charged with first-degree assault and unlawful use of a weapon following a stabbing incident. The central issue at trial was whether the defendant acted in self-defense. The prosecution argued that the defendant was the initial aggressor, which would negate the self-defense claim. The trial court instructed the jury using Uniform Criminal Jury Instruction (UCrJI) 1110, which did not define the term "initial aggressor." During closing arguments, the prosecutor incorrectly suggested that being an initial aggressor could be determined by words alone, not just physical actions. The defendant did not object to the prosecutor's statements or request a supplemental instruction to define "initial aggressor."The defendant appealed, arguing that the trial court erred by not defining "initial aggressor" for the jury. The Oregon Court of Appeals agreed, holding that the trial court's failure to provide a definition amounted to plain error under the first prong of the Ailes v. Portland Meadows, Inc. decision. The Court of Appeals reversed the trial court's judgment, concluding that the trial court should have sua sponte provided a definition for "initial aggressor."The Oregon Supreme Court reviewed the case and reversed the Court of Appeals' decision. The Supreme Court held that the trial court did not commit plain error by failing to give an unrequested custom supplemental instruction. The court explained that UCrJI 1110 was a correct statement of the law and that the trial court's duty to instruct the jury does not extend to providing definitions for terms unless the given instruction is legally incorrect. The Supreme Court emphasized that plain error review requires the error to be apparent on the record, and without a requested supplemental instruction, it is impossible to determine if the trial court's failure to provide one was legally incorrect. Therefore, the judgment of the circuit court was affirmed. View "State v. Worsham" on Justia Law

Hector Cervantes-Torres was convicted in 2014 of being a felon in possession of a firearm, possessing a firearm as an alien unlawfully present in the United States, and being an alien found unlawfully present in the United States following deportation. Five years later, the Supreme Court ruled in Rehaif v. United States that a defendant’s knowledge of their status as a person barred from possessing a firearm is a necessary element of a § 922(g) conviction. Cervantes-Torres filed a coram nobis petition in 2021 to vacate his § 922(g)(1) and § 922(g)(5) convictions due to the lack of a Rehaif instruction at his trial.The district court granted the petition for the § 922(g)(1) conviction but denied it for the § 922(g)(5) conviction. The court found that there was a reasonable probability that the jury could have reached a different verdict regarding the § 922(g)(1) conviction due to the expungement of Cervantes-Torres’s felony drug conviction. However, for the § 922(g)(5) conviction, the court concluded that no reasonable jury could find that Cervantes-Torres was unaware of his unlawful status, given his deportation, false statements on his green card application, and a letter from USCIS informing him of his lack of lawful status.The United States Court of Appeals for the Ninth Circuit affirmed the district court’s partial denial of Cervantes-Torres’s petition. The panel held that even under the standard of review for a direct appeal, Cervantes-Torres could not prevail. The court found that there was no reasonable probability that the jury would have reached a different result even if a Rehaif instruction had been given, due to the overwhelming evidence that Cervantes-Torres was aware of his unlawful status. Therefore, any error from the lack of a Rehaif instruction was not of the most fundamental character, and the district court’s decision was affirmed. View "Cervantes-Torres v. United States" on Justia Law

Lugene Shipp and Dione Mobley were charged with conspiring to distribute heroin resulting in death and distribution resulting in death after M.W. died of heroin intoxication. M.W. had purchased heroin from Kami Kinzenbach, who sourced it from Shipp and Mobley. M.W. was found dead in his bedroom with heroin and fentanyl residue. An autopsy confirmed heroin intoxication as the cause of death. Kinzenbach's testimony and electronic messages linked Shipp and Mobley to the heroin sold to M.W.The United States District Court for the Southern District of Iowa conducted a bench trial, convicting Shipp on both counts and Mobley only on the conspiracy count. Shipp and Mobley challenged their convictions based on evidentiary rulings, the Confrontation Clause, and sufficiency of the evidence. Mobley also argued that the district court erroneously relied on acquitted conduct at sentencing.The United States Court of Appeals for the Eighth Circuit reviewed the case. The court found that the district court did not err in admitting the electronic messages from M.W. and Sidnee, as they were either not hearsay or fell under hearsay exceptions. The court also concluded that the admission of these statements did not violate the Confrontation Clause since they were not testimonial. Additionally, the court held that there was sufficient evidence to prove that the heroin distributed by Shipp caused M.W.'s death, rejecting the defendants' speculative claims about other potential sources of heroin.Regarding Mobley's sentencing, the court determined that the district court properly considered M.W.'s death and drug quantities associated with the conspiracy, as Mobley was convicted of conspiring to distribute heroin resulting in death. The court affirmed the convictions and sentences of both Shipp and Mobley. View "United States v. Shipp" on Justia Law

Principal Springer was involved in drug dealing within 1,000 feet of a school and had multiple firearms in his apartment. Following a lengthy investigation, a search of his apartment revealed drugs, drug paraphernalia, and firearms. He was charged with conspiring to deal drugs within a school zone and unlawfully possessing firearms due to his drug use and a prior misdemeanor domestic-violence conviction. Springer moved to dismiss the firearm count, arguing that the restrictions violated the Second Amendment. The district court disagreed, and Springer pleaded guilty while reserving the right to appeal his Second Amendment challenges. He was sentenced to 110 months in prison.The United States District Court for the Northern District of Iowa denied Springer’s motion to dismiss the firearm count. Springer then pleaded guilty but reserved his right to appeal the Second Amendment issues. He received concurrent sentences of 110 months in prison.The United States Court of Appeals for the Eighth Circuit reviewed the case. The court held that the statute prohibiting drug users from possessing firearms, 18 U.S.C. § 922(g)(3), is not facially unconstitutional, referencing its previous decision in United States v. Veasley. The court also rejected Springer’s as-applied challenge to the statute prohibiting domestic abusers from possessing firearms, 18 U.S.C. § 922(g)(9), noting that a conviction under any one of the § 922(g) categories is sufficient. Additionally, the court found no abuse of discretion in the district court’s decision not to grant a downward variance in sentencing. The Eighth Circuit affirmed the judgment of the district court. View "United States v. Springer" on Justia Law

John Padgett was convicted of malice murder for the strangling death of his former girlfriend, Wynesha Medley. Medley ended their relationship in November 2016, after which Padgett sent her aggressive messages and visited her apartment uninvited. On January 23, 2017, Medley reported to the police that she believed Padgett had turned off her power. The next day, Medley was found dead in her apartment with a pair of leggings around her neck. Forensic evidence linked Padgett to the crime scene, including his DNA under Medley’s fingernails and cell phone location data placing him near her apartment at relevant times.A Chatham County grand jury indicted Padgett for malice murder, felony murder, and aggravated assault. In May 2021, a jury found him guilty on all counts, and he was sentenced to life in prison without parole. Padgett filed a motion for a new trial, which was denied after a hearing in September 2024. He then appealed to the Supreme Court of Georgia.The Supreme Court of Georgia reviewed Padgett’s claims of ineffective assistance of counsel. Padgett argued that his trial counsel failed to emphasize certain DNA evidence, investigate and present evidence about another potential suspect, and object to the prosecutor’s statements during closing arguments. The court found that the decisions made by Padgett’s trial counsel were strategic and not deficient. Additionally, Padgett failed to show that the outcome of his trial would have been different if his counsel had acted differently. The court concluded that Padgett did not demonstrate prejudice from his counsel’s performance and affirmed the conviction. View "PADGETT v. THE STATE" on Justia Law

Keitran Foots was convicted of malice murder and other offenses related to the shooting death of Sharika Bowman. The incident occurred on March 30, 2018, and Foots was indicted in October 2018. The charges included malice murder, two counts of felony murder, aggravated assault family violence, possession of a firearm by a convicted felon, and possession of a firearm during the commission of a felony. The jury found Foots guilty on all counts, and he was sentenced to life in prison without the possibility of parole for malice murder, along with concurrent terms for the other offenses.Foots filed a motion for a new trial, which was denied by the trial court. He then filed a timely notice of appeal. The Supreme Court of Georgia reviewed the case, focusing on two claims of error related to the trial court's handling of a voluntary manslaughter instruction and the sufficiency of the evidence supporting his convictions. The court noted that any challenge to the felony murder counts was moot because those counts were vacated by operation of law when the trial court entered a sentence on the malice murder count.The Supreme Court of Georgia held that the evidence presented at trial was sufficient to support Foots's convictions. The court emphasized that the jury was authorized to reject Foots's self-defense claim based on his testimony and the corroborative evidence, including his actions after the shooting, such as fleeing the scene and leading police on a high-speed chase. The court affirmed the judgment, concluding that the evidence was sufficient to support the convictions for malice murder, aggravated assault family violence, and firearms offenses. View "FOOTS v. THE STATE" on Justia Law

Taj Dialo Gayle was convicted of felony murder predicated on kidnapping in connection with the shooting death of Melanie Steele. Steele was killed on September 13, 2019. Gayle, along with John Bailey, Justin Path, and Marcus Wilson, was indicted for various crimes related to Steele’s death. Gayle faced charges including felony murder, kidnapping, armed robbery, and possession of a firearm during the commission of a felony. Wilson pleaded guilty to reduced charges and testified against Gayle. The State dropped the armed robbery and firearm charges before trial. At the joint trial of Gayle and Bailey, the jury found Gayle guilty of felony murder and kidnapping. The trial court merged the kidnapping charge into the felony murder charge and sentenced Gayle to life in prison without parole.Gayle filed a motion for a new trial, which was denied by the trial court. He then appealed to the Supreme Court of Georgia, arguing that the evidence was insufficient because Wilson’s testimony, as an accomplice, was not corroborated.The Supreme Court of Georgia affirmed the conviction. The court held that the jury could have reasonably found that Wilson was not an accomplice, as his testimony indicated he was unaware of the plan to kidnap and shoot Steele until it happened. The court noted that when the issue of whether a witness was an accomplice is submitted to the jury and there is evidence allowing the jury to find that the witness was not an accomplice, corroborating evidence is not required to sustain a guilty verdict. Therefore, the evidence was sufficient to support Gayle’s conviction. View "GAYLE v. THE STATE" on Justia Law

Andrew Wilson was convicted of malice murder and other crimes related to the asphyxiation and burning of Gregory Harris. Wilson appealed, arguing that the trial court improperly admitted evidence of a prior armed robbery he committed. The Supreme Court of Georgia reviewed the case.Initially, a Fulton County grand jury indicted Wilson and Edgar Hubbard for multiple crimes, including malice murder and arson. Hubbard was tried first and convicted of arson. Wilson was tried separately and found guilty on all counts. He was sentenced to life without parole for malice murder, with additional concurrent sentences for arson and theft by receiving stolen property. Wilson's motion for a new trial was denied, leading to this appeal.The Supreme Court of Georgia found that the trial court abused its discretion by admitting evidence of Wilson’s prior armed robbery under OCGA § 24-4-404 (b). The court determined that this error was not harmless and reversed Wilson’s convictions. However, the court concluded that the evidence was constitutionally sufficient to support the jury’s guilty verdicts on all counts except for theft by receiving stolen property. Therefore, Wilson may be retried on all counts except for theft by receiving.Additionally, the court addressed Wilson’s claim regarding the denial of his motion to suppress evidence derived from his cell phone records. The court found no error in the trial court’s decision to deny the motion to suppress, as the records were obtained in good faith under the Stored Communications Act, which was valid at the time.In summary, the Supreme Court of Georgia reversed Wilson’s convictions due to the improper admission of prior bad act evidence, but allowed for a retrial on all counts except theft by receiving stolen property. The court upheld the trial court’s decision on the admissibility of cell phone records. View "WILSON v. THE STATE" on Justia Law

Abraham Quintanar was convicted of felony murder and other crimes related to the shooting death of Marcus Gilead and the attempted armed robbery of Ciavy Wiles. On February 10, 2020, Quintanar, along with co-indictees Miguel Angel Gonzalez and Sebastian Resendiz-Garcia, attempted to rob Gilead and Wiles at gunpoint. During the robbery, Quintanar and Gilead struggled for control of Quintanar’s gun, resulting in Quintanar shooting and killing Gilead. Quintanar was indicted on multiple charges, including felony murder, aggravated assault, and possession of a firearm. He was tried separately and found guilty on all counts, receiving a life sentence with the possibility of parole for felony murder, among other sentences.The trial court admitted Quintanar’s custodial statement, testimony about a video recording not introduced into evidence, and denied certain impeachment of a witness. The court also refused to give requested jury charges related to justification and mutual combat. Quintanar argued that these decisions, along with portions of the State’s closing argument, amounted to plain error and cumulative prejudice.The Supreme Court of Georgia reviewed the case and found that the trial court did not err in admitting Quintanar’s custodial statement, as it was deemed voluntary under the totality of the circumstances. The court also found that any error in admitting testimony about the video recording was harmless, as it was cumulative of other evidence. Additionally, the court held that the trial court did not abuse its discretion in limiting cross-examination of Resendiz-Garcia and that the evidence did not support Quintanar’s requested jury charges on self-defense and mutual combat.The Supreme Court of Georgia affirmed Quintanar’s convictions but vacated his conviction and sentence for aggravated assault, as it should have merged with his conviction for attempted armed robbery. View "QUINTANAR v. THE STATE" on Justia Law