Justia Criminal Law Opinion Summaries

The case concerns a man convicted of conspiracy to commit robbery in the first degree, attempt to commit robbery in the first degree, and assault in the first degree after a pizza delivery driver was shot. The prosecution’s theory was that the defendant, while visiting a friend, used that friend’s cell phone to place calls to restaurants to target a delivery driver for robbery. A key witness, the friend, testified that the defendant used his phone to order the pizza, and a detective corroborated that the phone was used to call the pizza restaurant. The defense argued that the friend, not the defendant, committed the offenses, and the defendant also presented an alibi defense.Following his conviction, the defendant filed a habeas petition in the Superior Court for the judicial district of Tolland, alleging ineffective assistance of counsel due to his trial counsel’s failure to investigate the friend’s cell phone records and to present additional alibi witnesses. The habeas court denied relief, and the Appellate Court affirmed. While the Appellate Court agreed that counsel’s performance regarding the phone records was deficient, a majority found no prejudice, reasoning that the outcome would not have changed. A dissenting judge disagreed, finding that the phone records could have undermined key testimony.The Supreme Court of Connecticut reviewed the case and held that the Appellate Court erred in concluding that the defendant failed to establish prejudice from counsel’s failure to investigate and present the phone records. The Supreme Court found a reasonable probability that the outcome would have differed had the records been introduced, as they would have seriously undermined the prosecution’s case and supported the defense theory. The Supreme Court reversed the Appellate Court’s judgment and directed that the habeas court grant the petition, vacate the convictions, and order a new trial. View "Grant v. Commissioner of Correction" on Justia Law

The defendant was convicted of five counts of sexual assault in the first degree and two counts of risk of injury to a child, based on multiple incidents of sexual abuse against two minor victims who attended a day care operated by the defendant’s wife in their home. The abuse occurred over several years, when the victims were between three and eight years old. The state’s case relied on evidence that the defendant committed a variety of sexual acts against each child on separate occasions. Each count of sexual assault was based on multiple, distinct incidents involving a specific sexual act.The Superior Court for the judicial district of New Haven conducted a jury trial. At the conclusion of evidence, the trial court provided the jury with specific unanimity instructions for each count, stating that to find the defendant guilty, all jurors must unanimously agree that the defendant committed at least one specific alleged act described in the count. The jury returned guilty verdicts on all counts, and the court sentenced the defendant to a total effective term of twenty-five years’ imprisonment, execution suspended after twenty-one years, followed by ten years of probation. The defendant appealed directly to the Connecticut Supreme Court, arguing his right to a unanimous jury verdict was violated because the trial court did not require the jury to answer special interrogatories identifying which incident formed the basis for each conviction.The Supreme Court of Connecticut held that the federal constitution does not require special interrogatories on unanimity in addition to a specific unanimity instruction when a single count is based on multiple, separate acts. The Court found the trial court’s unanimity instructions sufficient to protect the defendant’s constitutional rights and affirmed the judgments. View "State v. Carlos G." on Justia Law

The case concerned a man charged with murder, burglary, conspiracy, and tampering with evidence after the decomposed body of a woman with whom he had an intimate relationship was discovered. The investigation revealed that he and his girlfriend devised and executed a plan to kill the woman, subsequently disposing of her body and attempting to destroy evidence. The defendant was interviewed by police on three occasions. During the second interview, after waiving his Miranda rights, he made incriminating statements and then invoked his right to remain silent. The next morning, while awaiting arraignment, the defendant initiated a third interview, during which he made an equivocal reference to counsel, received renewed Miranda warnings, and then confessed.The Superior Court for the judicial district of Waterbury denied the defendant’s motion to suppress statements from the third interview and his cell phone records. The jury found the defendant guilty of murder, burglary, conspiracy to commit burglary, and tampering with evidence; the court vacated the conspiracy to commit tampering conviction at sentencing. The defendant appealed directly to the Connecticut Supreme Court, arguing that the trial court improperly admitted his September 23 interview (second interview), failed to suppress the September 24 interview confession (third interview), and wrongly admitted his cell phone records.The Supreme Court of Connecticut affirmed the trial court’s judgment. It held that defense counsel had affirmatively waived any Miranda-based challenge to the September 23 interview. Regarding the September 24 interview, the Court concluded that the detective’s renewed Miranda advisement adequately clarified the defendant’s equivocal request for counsel, and his written waiver manifested a clear desire to proceed without counsel. The Court also held that the search warrant for cell phone records was supported by probable cause, was sufficiently particular, and did not authorize a general search. The defendant’s additional constitutional claims were also rejected. View "State v. Johnson" on Justia Law

A man was convicted for the shooting death of another individual following an altercation that began after the victim drove past a group of people, including the defendant, with a loud noise from his truck. The defendant followed the victim, confronted him, and after a struggle over a BB gun, fired several shots, killing the victim. At trial, the defendant asserted that he acted in self-defense, claiming he believed the victim was about to shoot him with the BB gun.The case was tried in the Superior Court in the judicial district of New Haven. The jury acquitted the defendant of murder but found him guilty of the lesser included offense of intentional manslaughter in the first degree with a firearm, as well as carrying a pistol or revolver without a permit, and criminal possession of a firearm. The defendant was sentenced to a total effective sentence of thirty-three years imprisonment. He appealed his conviction, raising claims regarding jury instructions and sufficiency of the evidence.The Supreme Court of Connecticut reviewed the defendant’s claims. The court held that the federal constitution does not require jury unanimity as to which specific statutory disqualification to self-defense the state has proven, so long as the jurors unanimously agree that the state has disproved the defense of self-defense beyond a reasonable doubt. The court further found that the trial court’s jury instructions were not misleading regarding the initial aggressor doctrine, the “words alone” principle, or the state of mind required for lesser included offenses. Finally, the Supreme Court concluded that there was sufficient evidence for the jury to find that the defendant did not justifiably act in self-defense and that he acted with specific intent to cause serious physical injury. Accordingly, the judgment of conviction was affirmed. View "State v. Matheney" on Justia Law

The case concerns a petitioner who was convicted of felony murder, robbery in the first degree, and conspiracy to commit robbery in the first degree, stemming from the fatal shooting of a man who had arranged to sell electronic tablets via Craigslist. The victim was lured to a location in Hartford, where he was shot and killed during an attempted robbery. Evidence at trial included statements and admissions by the petitioner, testimony linking him to the scene, and communications involving his alleged coconspirator, Mathis. After the petitioner’s conviction, Mathis was tried separately and found not guilty by reason of mental disease or defect, under a Connecticut statute that excuses criminal liability if a defendant, due to mental impairment, cannot appreciate the wrongfulness of his actions or conform his conduct to the law.After his conviction was affirmed on direct appeal, the petitioner sought habeas corpus relief in the Superior Court for the judicial district of Tolland, arguing that Mathis’s subsequent acquittal and the evidence from Mathis’s trial constituted newly discovered evidence proving the petitioner’s actual innocence, as a valid conspiracy under Connecticut law requires both parties to possess criminal intent. The habeas court denied relief, concluding that Mathis’s acquittal was legally irrelevant based on precedent allowing inconsistent verdicts for separately tried coconspirators. The Appellate Court disagreed with the habeas court’s reasoning, holding that evidence from Mathis’s trial should be considered in the actual innocence analysis. However, it affirmed the denial of habeas relief on the alternative ground that there was sufficient evidence of a conspiracy between the petitioner and a third party.The Connecticut Supreme Court reviewed the case. It held that, while the Appellate Court correctly required consideration of all aggregate evidence, Mathis’s acquittal did not clearly and convincingly demonstrate Mathis’s incapacity to form criminal intent, as the acquittal was based on a lower standard of proof and did not necessarily negate specific intent. Therefore, the petitioner failed to meet the high burden of proving actual innocence, and the judgment was affirmed. View "Moon v. Commissioner of Correction" on Justia Law

The case involves a defendant who was convicted by a jury of manslaughter in the first degree with a firearm after shooting his girlfriend in the head with a revolver while she was sitting in a small bathroom of their shared residence. The prosecution presented forensic evidence suggesting the defendant pressed the loaded, fully-cocked revolver against the victim’s head before firing. The defense argued the shooting was accidental, claiming the gun—known to have a very light “hair trigger”—discharged when the defendant tripped on the bathroom doorframe while holding it.The Superior Court for the judicial district of New Haven conducted the trial, and the jury found the defendant guilty. The trial court did not provide an express jury instruction on general intent, and neither party requested one. The defendant appealed to the Connecticut Appellate Court, arguing under the plain error doctrine that the absence of a general intent instruction required reversal. The Appellate Court agreed, finding that the jury could have convicted the defendant without determining whether his actions were volitional, and reversed the conviction, ordering a new trial.The Supreme Court of Connecticut reviewed the case upon the state’s appeal. The Supreme Court held that the trial court’s failure to provide a stand-alone general intent instruction did not constitute plain error. The Court reasoned that the element of general intent was necessarily included in the instruction on recklessness, which required the jury to find that the defendant acted with awareness and conscious disregard of a substantial risk. The Supreme Court concluded that the omission did not result in a manifest injustice and reversed the Appellate Court’s judgment, directing it to affirm the conviction. View "State v. Anthony V." on Justia Law

In this case, the defendant completed a federal prison sentence for a prior firearm conviction and then began supervised release. During this supervised period, he was found in possession of a firearm and ammunition, which led to the initiation of revocation proceedings for violating the terms of his supervised release. Shortly thereafter, a search of his residence yielded additional ammunition. These events resulted in new criminal charges for possession of a firearm by a prohibited person under 18 U.S.C. § 922(g)(1). The defendant pleaded guilty to the new charge pursuant to a plea agreement and also faced sentencing for the supervised release violations.Previously, the United States District Court for the District of Puerto Rico sentenced the defendant both for the new § 922(g)(1) offense and for the supervised release violations. The defendant appealed, and the United States Court of Appeals for the First Circuit (in United States v. Rosa-Borges, 101 F.4th 66 (1st Cir. 2024)) vacated both sentences, finding that the district court had improperly relied on unreliable hearsay from the presentence report. On remand, the district court refused to strike the problematic information from the presentence report but stated it would not rely on it, then reimposed an upwardly variant sentence for the new firearm offense, in part based on the amount and nature of the ammunition. For the supervised release violation, the court imposed a consecutive sentence, finding a Grade A violation.Upon the second appeal, the United States Court of Appeals for the First Circuit affirmed the revocation sentence, concluding that the defendant had waived his challenges to that sentence. However, the appellate court vacated the sentence for the § 922(g)(1) conviction, holding that the district court relied on a legally invalid rationale—namely, treating 31 rounds of ammunition as an aggravating factor and referencing unsupported facts about the ammunition’s nature. The case was remanded for resentencing before a different judge. View "United States v. Rosa-Borges" on Justia Law

The case concerns an individual who, along with a companion, was involved in the unauthorized taking of a company vehicle from a hotel parking lot in West Virginia in May 2021. The companion misrepresented herself as an employee to obtain the car keys from hotel staff, while the petitioner was present in the lobby. The two left together, and the vehicle was later tracked and found by police, who arrested both individuals. During his arrest, the individual volunteered information to police that he was on supervised release for a prior federal conviction.In the Circuit Court of Harrison County, the petitioner moved to exclude references to his federal supervised release status from bodycam footage to be shown at trial. Both the prosecution and defense agreed this information should be redacted, as it was not relevant to the charges. However, the circuit court denied the motion, finding the evidence to be “intrinsic” to the crime. The unredacted footage was admitted at trial, and the jury returned guilty verdicts for grand larceny and conspiracy to commit grand larceny.The Supreme Court of Appeals of West Virginia reviewed the case and concluded that the circuit court abused its discretion by admitting the bodycam audio referencing the petitioner’s supervised release. The high court found this evidence was not intrinsic to the charged crimes, was irrelevant and inadmissible under Rule 404(b) of the West Virginia Rules of Evidence, and that its admission was prejudicial, given the circumstantial nature of the remaining evidence. The Supreme Court of Appeals held that the error was not harmless and reversed the convictions, remanding for a new trial. View "State v. Paglia" on Justia Law

Steven Clark Lefemine participated in an anti-abortion protest at a reproductive healthcare facility in Columbia, South Carolina, where he intentionally blocked the entrance by sitting in front of the doorway, preventing patients and staff from entering. After refusing requests to move, the police were called, and Lefemine was arrested. He was initially charged with trespassing under state law, for which he was fined, and subsequently indicted by a federal grand jury for violating the Freedom of Access to Clinic Entrances Act (FACE Act) under 18 U.S.C. § 248.In the United States District Court for the District of South Carolina, Lefemine was first charged under a provision of the FACE Act carrying a maximum penalty of one year in prison. However, the government amended the penalty sheet—an auxiliary document to the indictment—to reflect a lower maximum penalty: six months’ imprisonment and/or a fine of $10,000. The indictment was also amended to conform to this reduced penalty. Lefemine’s counsel acknowledged and consented to these amendments. The district court denied Lefemine’s request for a jury trial, finding that the charged offense was a “petty” offense not subject to the Sixth Amendment right to a jury trial, and proceeded with a bench trial that resulted in Lefemine’s conviction.On appeal to the United States Court of Appeals for the Fourth Circuit, Lefemine argued that he was entitled to a jury trial both because of the original indictment and because Congress intended all FACE Act violations to require a jury trial. The Fourth Circuit held that the amendments did not require resubmission to a grand jury and that the maximum penalty Lefemine faced rendered the offense “petty” under Supreme Court precedent. The court affirmed that the first-time, nonviolent exception under the FACE Act does not require a jury trial, joining the Second, Seventh, and Eleventh Circuits, and affirmed the district court’s judgment. View "United States v. Lefemine" on Justia Law

Two brothers were affiliated with a group engaged in ongoing gun violence with a rival group in Abbeville, Louisiana. About a year and a half after two shooting incidents involving one brother, a drive-by shooting occurred in a parking lot, resulting in the death of Jazaylon Levy. Video surveillance, witness testimony, vehicle measurements, and forensic evidence linked the brothers to a silver Mercedes-Benz seen at the scene and leaving shortly after the shooting. The evidence suggested the brothers intended to target a rival group associate and that one acted as the driver while the other fired the shots, causing Levy’s death.The case was tried in the District Court for the Parish of Vermilion, where a unanimous jury convicted both brothers of second degree murder. The trial judge imposed life sentences at hard labor without benefit of parole, probation, or suspension of sentence. After post-verdict motions were denied, the defendants appealed to the Louisiana Court of Appeal, Third Circuit. That court reversed the convictions, finding the evidence insufficient, particularly because the State had not excluded every reasonable hypothesis of innocence and misidentification, and the jury’s verdict was based on speculation.The Supreme Court of Louisiana reviewed the case on writ of certiorari. Applying the Jackson v. Virginia standard, the court held that, viewing the evidence in the light most favorable to the prosecution, a rational trier of fact could have found the defendants guilty beyond a reasonable doubt, and that the State had excluded every reasonable hypothesis of innocence. The court found the appellate court erred by substituting its judgment for the jury’s and reinstated the convictions and sentences, remanding the case to the appellate court to consider the defendants’ remaining assignments of error. View "STATE OF LOUISIANA VS. BRIGGS" on Justia Law