Justia Criminal Law Opinion Summaries

A man was accused by his fiancée’s daughter, “Jane,” of sexually abusing her over several years, beginning when she was four years old. The allegations surfaced after Jane confided in a friend, leading to a criminal investigation. The investigation resulted in the discovery of web bookmarks with pornographic and incestuous titles on the man’s phone and computers. At trial, the prosecution presented testimony from Jane and others about sexual misconduct, as well as evidence of the bookmarks. The man denied the allegations, claiming Jane’s mother fabricated the accusations as part of a custody dispute.The Ellsworth District Court admitted the web bookmark evidence over the defense’s objection, finding it relevant to the charges requiring proof of sexual intent. The jury convicted the defendant on multiple counts, including aggravated criminal sodomy and related offenses. The district court sentenced him to life imprisonment without parole for 50 years, plus a consecutive term. On appeal, the Kansas Court of Appeals affirmed the convictions, upholding the admission of the web bookmarks and finding no prejudicial prosecutorial error or cumulative error.The Supreme Court of the State of Kansas reviewed the case after granting further review. The court held that the web bookmark evidence was properly admitted because it was material and probative to the charged offenses, particularly those requiring proof of sexual intent. The court also found that a prosecutor’s “golden rule” argument during closing was error but deemed it harmless in light of the strong evidence against the defendant. The court further held that, even considering another harmless evidentiary error identified by the Court of Appeals, there was no cumulative error sufficient to deny the defendant a fair trial. The Supreme Court affirmed both the Court of Appeals’ and the district court’s judgments. View "State v. Cunningham " on Justia Law

A Malaysian national who worked as a managing director for Goldman Sachs in Malaysia was prosecuted for his role in a large-scale financial scheme involving 1Malaysia Development Berhad (1MDB), a Malaysian state-owned investment fund. The government presented evidence showing that, along with other conspirators, he participated in three major bond offerings raising $6.5 billion, from which more than $2.5 billion was diverted for bribes and kickbacks to officials and participants, including himself. The funds were laundered through shell companies, and the defendant received $35.1 million that was deposited in an account controlled by his family members. The defendant’s wife asserted at trial that these funds were legitimate investment returns, not criminal proceeds.Prior to this appeal, the United States District Court for the Eastern District of New York denied several motions by the defendant. The court rejected his arguments that the indictment should be dismissed for lack of venue, concluding that acts in furtherance of the conspiracy passed through the Eastern District of New York. The court also found that the government did not breach an agreement regarding his extradition from Malaysia, since the superseding indictments did not charge new offenses. The district court excluded a video recording offered by the defense as inadmissible hearsay, and ultimately, a jury found him guilty on all counts. He was sentenced to 120 months’ imprisonment and ordered to forfeit $35.1 million.On appeal to the United States Court of Appeals for the Second Circuit, the defendant argued improper venue, breach of extradition agreement, erroneous exclusion of evidence, and that the forfeiture was an excessive fine under the Eighth Amendment. The Second Circuit held that the district court had not erred in any respect. Venue was proper, the extradition agreement was not breached, the evidentiary ruling was not an abuse of discretion, and the forfeiture was not grossly disproportionate to the offense. Accordingly, the judgment of conviction and forfeiture order were affirmed. View "USA v. NG CHONG HWA" on Justia Law

A man was stopped by police while walking along a road after a report of a violent incident involving a vehicle and a fleeing suspect. The man matched the description of the person who fled the scene. Without first giving Miranda warnings, an officer handcuffed him and questioned him briefly at the roadside, where he made limited admissions about a fight. Hours later, at the police station, different officers gave him Miranda warnings, obtained a signed waiver, and questioned him further. During this interview, the man made additional incriminating statements. He was later indicted for two forms of second degree murder based on the death of the other individual involved in the incident.The Superior Court partially granted and partially denied the defendant’s motion to suppress his statements. It suppressed the initial roadside statements, finding a Miranda violation, and also suppressed statements made after the defendant invoked his right to remain silent. However, the court found that the post-Miranda statements made at the police station were voluntary and admissible. At trial, the jury convicted the defendant of reckless second degree murder and acquitted him of knowing second degree murder. The defendant also objected to the admission of certain recorded jail calls, arguing they were irrelevant.The Supreme Court of New Hampshire reviewed whether the trial court erred in admitting the post-Miranda interview statements and the jail calls. The court held that the trial court’s finding that the defendant’s post-Miranda statements were voluntary was not against the manifest weight of the evidence, considering the circumstances and the break between interviews. Regarding the jail calls, the court held that even assuming error in admitting certain portions, any such error was harmless beyond a reasonable doubt due to overwhelming evidence of guilt. The conviction was affirmed. View "State v. Sleeper" on Justia Law

In November 2018, police and firefighters responded to a fire at the defendant’s home. About forty minutes after their arrival, while the main section of the house remained ablaze, officers seized a digital video recorder (DVR) from the garage attached to the house without first obtaining a warrant. The State alleged that the DVR contained footage relevant to a broader investigation, including suspicion of arson and multiple related homicides. The defendant moved before trial to suppress the DVR, arguing that its warrantless seizure was unconstitutional.The Superior Court, Law Division held a multi-day suppression hearing, heard testimony from several first responders, and reviewed video and photographic evidence. The trial judge found the officers credible but determined that exigent circumstances did not justify the warrantless seizure because the garage fire had been extinguished for about thirty minutes and the garage was physically distant from the still-burning portion of the house. The Appellate Division affirmed, agreeing that the officers had time to secure a warrant and that the facts did not support an objectively reasonable belief that immediate seizure was necessary.The Supreme Court of New Jersey reviewed the case and, applying a de novo standard to the legal conclusions, found that under the totality of the circumstances, the police acted reasonably and that exigent circumstances justified the warrantless seizure of the DVR. The Court explained that no bright-line rule governs exigency, and its determination requires a fact-sensitive analysis. Here, the seriousness of the crime, the urgency of the situation, the difficulty of obtaining a warrant at that hour, and the risk of evidence destruction supported the officers’ actions. The Court reversed the suppression order and remanded for further proceedings. View "State v. Caneiro" on Justia Law

Gene Roper, a convicted sex offender, was required to register his location under the Sex Offender Registration Notification Act due to a prior conviction for attempted lewdness with a child under 14. After repeated violations of registration requirements and additional criminal conduct, including multiple failures to register, resisting arrest, and battery, Roper moved from Nevada to Tennessee without notifying authorities, resulting in his fourth failure-to-register offense. His history also included significant mental health challenges, homelessness, and substance abuse issues.The United States District Court for the Eastern District of Tennessee accepted Roper’s guilty plea to the federal failure-to-register charge. At sentencing, the court imposed a 30-month prison term, which Roper did not appeal. However, the court also ordered a 20-year term of supervised release, exceeding the five-year period recommended by the Sentencing Guidelines but remaining under the statutory maximum of life. The district court justified this decision by referencing Roper’s mental health needs, criminal history, repeated noncompliance with prior supervision, and risk to public safety. The court also ordered conditions such as mental health treatment and substance abuse testing.Roper appealed to the United States Court of Appeals for the Sixth Circuit, arguing that the district court erred procedurally by relying on his mental illness to lengthen his supervised release, and that the sentence was substantively unreasonable. The Sixth Circuit held that it was permissible for the district court to consider mental health issues as one factor among several when determining the length of supervised release. The appellate court found no abuse of discretion in the district court’s justification and affirmed the 20-year term, concluding that it was reasonable under the circumstances and did not violate statutory or constitutional limits. View "United States v. Roper" on Justia Law

A lawful permanent resident from Mexico entered the United States in 2016 and, in 2024, pleaded guilty to eight criminal offenses in New Mexico, including child abuse and aggravated assault with a deadly weapon. The child abuse conviction was based on an incident in which he punched a child in the lip. The aggregate sentence for all convictions was approximately 21.5 years. Following these convictions, the Department of Homeland Security initiated removal proceedings, alleging that his child abuse conviction qualified as a removable offense under federal law, and that the aggravated assault conviction constituted an aggravated felony.An Immigration Judge denied the petitioner’s motion to terminate the proceedings, sustaining both charges of removability. The petitioner’s counsel declined to seek any further relief from removal, reserving only the right to appeal. The Board of Immigration Appeals considered the case next, focusing on whether the New Mexico child abuse statute fit the federal definition of a removable “crime of child abuse.” Applying the categorical approach, the Board concluded that the statute matched the federal standard and dismissed the petitioner’s appeal, not addressing the aggravated assault conviction.The United States Court of Appeals for the Fifth Circuit reviewed the Board’s decision. The court held that the petitioner failed to show a realistic probability that New Mexico would apply its child abuse statute in a way broader than the federal definition. The court also determined that the petitioner was statutorily ineligible for cancellation of removal, regardless of whether his aggravated assault conviction constituted an aggravated felony, because he had multiple convictions with aggregate sentences exceeding five years within seven years of his admission as a permanent resident. Finding no basis for remand or relief, the Fifth Circuit denied the petition for review. View "Santiago v. Bondi" on Justia Law

Devon Holt was charged with being a felon in possession of a firearm after investigators obtained a warrant to search his Facebook account and found posts and messages referencing firearms. These included statements suggesting he was carrying a firearm and expressing motives related to self-protection and respect. Holt pleaded not guilty, and his case proceeded to trial. He objected to the admission of this Facebook content, arguing it was prejudicial, but the district court admitted some of the posts for the limited purpose of showing knowledge and motive, instructing the jury accordingly. The jury convicted Holt.The United States District Court for the District of Minnesota sentenced Holt to 42 months’ imprisonment, slightly above the minimum of the guideline range. Holt argued for a lower sentence, citing difficult pretrial detention conditions and uncertainty before sentencing. The district court explained its reasoning in detail, acknowledging both aggravating and mitigating factors, including Holt’s positive use of his time in jail. Holt then appealed, challenging both the admission of the Facebook evidence and the adequacy of the sentencing explanation.The United States Court of Appeals for the Eighth Circuit reviewed the district court’s evidentiary and sentencing decisions. It held that the Facebook content was properly admitted under Federal Rule of Evidence 404(b) because it was relevant to issues of Holt’s knowledge and motive and was not unfairly prejudicial. The appellate court also found that the district court gave a sufficiently detailed explanation for its sentencing decision, considered the relevant factors, and imposed a substantively reasonable sentence. Consequently, the Eighth Circuit affirmed both the conviction and the sentence. View "United States v. Holt" on Justia Law

Raphael Nunn was convicted of kidnapping, bank fraud, and aggravated identity theft based on three incidents involving separate victims. In the first incident, Nunn robbed C.L. at gunpoint and stole her purse, later using her bank cards for unauthorized purchases. The second incident involved the theft of J.T.’s backpack, which contained her bank cards, subsequently used without her permission. In the third incident, Nunn kidnapped S.E. from a parking garage, forced her to withdraw cash from a bank, and left her at a park. Law enforcement identified Nunn as the perpetrator in all three cases and arrested him.Prior to trial in the United States District Court for the District of Minnesota, Nunn moved to suppress statements made during a custodial interview, arguing he had invoked his right to counsel. The magistrate judge denied the motion, finding the invocation ambiguous, and the district court adopted this ruling. At trial, the government introduced Nunn’s interview statements and allowed C.L. to make a spontaneous in-court identification, to which Nunn did not object. The jury found Nunn guilty on all counts. The Presentence Investigation Report calculated an advisory guidelines range of 168 to 210 months plus a 24-month mandatory minimum. The district court varied upward, citing Nunn’s lengthy criminal history and imposed a total sentence of 288 months.On appeal, the United States Court of Appeals for the Eighth Circuit affirmed the conviction and sentence. The court held that the district court did not clearly err in denying the motion to suppress because Nunn’s statement was not an unambiguous invocation of his Miranda rights. The admission of C.L.’s in-court identification did not constitute plain error. Additionally, the district court did not abuse its discretion in imposing an above-guidelines sentence, properly weighing both aggravating and mitigating factors. View "United States v. Nunn" on Justia Law

A driver was involved in a traffic collision in Grand Forks County, North Dakota, which resulted in injuries to two people in another vehicle, including a minor who later died. Law enforcement, led by the North Dakota Highway Patrol, responded to the scene and investigated the driver for driving under the influence. During the investigation, a chemical breath test was administered to the driver to determine his blood alcohol content. The State later charged the driver with criminal vehicular injury and criminal vehicular homicide, both alleging he was driving under the influence.The District Court of Grand Forks County, Northeast Central Judicial District, held an evidentiary hearing on the driver's motion to suppress the results of the chemical breath test. The driver argued that his consent to the test was not voluntary and that the evidence was obtained in violation of statute and his due process rights. The court granted the motion, suppressing the breath test evidence, finding that the State failed to show that the driver voluntarily consented to the chemical test after being read the implied consent advisory.The North Dakota Supreme Court reviewed the District Court’s decision and applied a de novo standard to questions of law, while deferring to the lower court’s factual findings unless they were contrary to the manifest weight of the evidence. The Supreme Court held that the District Court misapplied the law by treating the relevant statutes—N.D.C.C. §§ 39-20-01 and 39-20-01.1—as separate and distinct rather than as statutes that operate in conjunction. The Supreme Court clarified that both statutes may apply simultaneously and that providing an accurate implied consent advisory does not constitute per se coercion. The Court reversed the suppression order and remanded the case for further findings on whether the driver’s consent was voluntary, using the correct legal standards. View "State v. Bell" on Justia Law

Lawrence Harris sought postconviction relief following his criminal conviction, arguing that his trial counsel was ineffective and that the State violated its obligations under Brady v. Maryland by failing to disclose favorable evidence—specifically, the probation conditions of a witness. Harris claimed that these alleged deficiencies undermined the fairness of his trial and warranted relief from his conviction.The District Court of Burleigh County, South Central Judicial District, reviewed Harris’s claims. Applying the standard from Strickland v. Washington, the district court found that Harris failed to demonstrate that any alleged errors by his trial counsel prejudiced the outcome of his case; in other words, he did not show a reasonable probability of a different result but for counsel’s unprofessional errors. Regarding the Brady claim, the court determined that Harris did not provide evidence that the State suppressed the witness’s probation conditions, and thus denied relief on that basis as well.On appeal, the Supreme Court of North Dakota considered Harris’s arguments. The Court affirmed the district court’s denial of postconviction relief. It held that the lower court’s findings regarding ineffective assistance of counsel were not clearly erroneous and were supported by evidence. Regarding the Brady claim, the Supreme Court concluded that Harris waived the issue by failing to meet the minimum briefing requirements under the North Dakota Rules of Appellate Procedure, as his appellate brief did not adequately articulate or support the claim. As a result, the Supreme Court declined to address the Brady claim on its merits and affirmed the district court’s order denying Harris’s application for postconviction relief. View "Harris v. State" on Justia Law