Justia Criminal Law Opinion Summaries

Two men were apprehended by the United States Coast Guard in international waters south of Puerto Rico after being observed jettisoning bales of cocaine from a vessel that lacked any indication of nationality. The Coast Guard recovered approximately 306 kilograms of cocaine and eventually transported the men, including the appellant, to St. Thomas in the U.S. Virgin Islands. The government asserted that the men were never brought to Puerto Rico, though the appellant disputed this. A grand jury in the District of the Virgin Islands indicted the appellant on multiple drug trafficking charges under the Maritime Drug Law Enforcement Act (MDLEA), as well as related offenses.The appellant moved to dismiss the indictment for improper venue, arguing that the MDLEA’s “any district” venue provision was unconstitutional and that venue was proper in Puerto Rico, where he claimed he was first brought. He also sought a pretrial evidentiary hearing on venue and the issuance of subpoenas for Coast Guard witnesses. The United States District Court of the Virgin Islands denied these motions, holding that the MDLEA’s venue provision was constitutional and that the Virgin Islands was a proper venue. The court also found that mere passage through Puerto Rico’s territorial waters did not constitute being “first brought” there under 18 U.S.C. § 3238, and denied the request for an evidentiary hearing, finding no colorable factual dispute that would affect the outcome.On appeal, the United States Court of Appeals for the Third Circuit reviewed the District Court’s decisions. The Third Circuit held that the MDLEA’s “any district” venue provision is constitutional, both facially and as applied, for offenses committed on the high seas. The court also found that the District Court did not abuse its discretion in denying a pretrial evidentiary hearing on venue. Accordingly, the Third Circuit affirmed the District Court’s orders. View "USA v. Cuevas-Almonte" on Justia Law

Police officers investigating a recent carjacking and kidnapping at an Oklahoma City motel received information from the motel manager that a man matching the suspect’s description was staying in a particular room. Upon arrival, one officer looked through a one-inch gap in the window curtains from an open-air walkway outside the room and saw the defendant, Cameron Watkins, sitting on a bed next to a handgun with an extended magazine. This observation led to Watkins’s arrest and the subsequent discovery of a firearm and ammunition in the room. Watkins was later charged with being a felon in possession of a firearm and, in a superseding indictment, with being a felon in possession of ammunition found at a separate crime scene.The United States District Court for the Western District of Oklahoma denied Watkins’s motion to suppress the evidence, finding that the officer’s observation was made from a public area—the motel’s exterior walkway—which was accessible to other guests and staff, and not part of the room’s curtilage. The court concluded there was no Fourth Amendment violation because the officer did not intrude upon a protected area or the defendant’s reasonable expectation of privacy. Watkins pleaded guilty to the firearm charge, reserving his right to appeal the suppression ruling, and was convicted by a jury on the ammunition charge.The United States Court of Appeals for the Tenth Circuit reviewed the case and affirmed both convictions. The court held that the officer’s visual observation through the window gap, made from a public walkway using only his unaided senses, did not constitute a search under the Fourth Amendment. The walkway was not curtilage, and the defendant did not have a reasonable expectation of privacy against such observation. The court therefore upheld the district court’s denial of the suppression motion and affirmed the convictions. View "United States v. Watkins" on Justia Law

The case concerns a man who, after being separated from his wife of six months, engaged in repeated and escalating contact with her, including hostile voicemails, text messages, and physically aggressive behavior such as banging on her door and damaging property. After being served with divorce papers, his conduct intensified, including following her, driving by her residence and her mother’s house, and sending threatening messages. One particular text message stated he had “nothing to lose,” would “go back to prison,” and would “die before I go back.” Law enforcement was contacted, and during a recorded conversation with an officer, he again referenced the possibility of returning to prison.The District Court of Sheridan County charged him with felony stalking, based on his conduct and a prior stalking conviction. The prosecution sought to introduce evidence under Wyoming Rule of Evidence 404(b), including the text and recorded statement referencing prison, to show intent, motive, and consciousness of guilt. The district court held a hearing, conducted the required analysis under Gleason v. State, and admitted the text and recorded statement for the stated purposes, while excluding other references to his prior conviction. At trial, the jury found him guilty, and he was sentenced to four to eight years in prison.On appeal, the Supreme Court of Wyoming reviewed whether the district court abused its discretion in admitting the text and recorded statement under W.R.E. 404(b). The court held that the district court properly admitted the evidence, as it was relevant to show intent, motive, and consciousness of guilt, and its probative value was not substantially outweighed by unfair prejudice. The Supreme Court of Wyoming affirmed the conviction. View "Bragdon v. The State of Wyoming" on Justia Law

A sheriff’s deputy in Geary County, Kansas, stopped a vehicle driven by Brian Beck after observing that a license plate frame partially obscured the state name on the plate. Beck was not committing any driving infractions. During the stop, Beck appeared nervous and gave an unusual explanation for his travel route. A canine unit was called, and after the dog alerted, Beck consented to a search of his car, which led to the discovery of over two pounds of methamphetamine. Beck was charged with possession with intent to distribute, possession without a drug tax stamp, and interference with law enforcement. He moved to suppress the evidence, arguing the stop was not supported by reasonable suspicion, but the Geary District Court denied the motion. At trial, Beck renewed his objection, which was again overruled, and a jury convicted him on all counts.On appeal, the Kansas Court of Appeals affirmed the convictions, holding that the partial obstruction of the state name justified the stop under Kansas law, specifically K.S.A. 8-133, which requires license plates to be “clearly visible” and “clearly legible.” The appellate panel reasoned that covering half of the state name violated the statute, regardless of whether the plate could otherwise be identified.The Supreme Court of the State of Kansas reviewed only the statutory interpretation issue. It held that Kansas law does not require the state name to be clearly legible on license plates, except as it appears on registration decals. The court found that the lower courts had misapplied the statute by treating the obscured state name as a violation. The Supreme Court reversed the decisions of both the district court and the Court of Appeals on this issue and remanded the case for further proceedings consistent with its interpretation of the statute. View "State v. Beck " on Justia Law

A police officer with the Metropolitan Police Department in Washington, D.C., was involved in two separate incidents within five days, during which he used neck restraints—specifically, trachea and carotid artery holds—on two individuals while on duty. Both incidents occurred at McDonald’s restaurants, and in each case, the officer initiated physical contact and applied prohibited neck restraints, despite the individuals not posing an immediate threat or actively resisting arrest. The officer was aware that such holds were forbidden by department policy, and in one instance, had been warned about his conduct just days before repeating it.A grand jury indicted the officer on five charges related to these events. Before trial, three charges were dropped. The United States District Court for the District of Columbia conducted a jury trial, after which the officer was convicted on two counts of depriving individuals of their rights under color of law, in violation of 18 U.S.C. § 242. The jury found that the officer acted willfully, used excessive force, and caused bodily injury. The court sentenced him to concurrent six-month prison terms and supervised release. The officer moved for acquittal and a new trial, arguing, among other things, that the jury instructions on willfulness were improper and that the evidence was insufficient. The District Court denied these motions.On appeal, the United States Court of Appeals for the District of Columbia Circuit reviewed the officer’s challenges. The court held that the jury instructions on willfulness were not plainly erroneous, as precedent allows conviction under § 242 for conduct done in reckless disregard of constitutional rights. The court also found sufficient evidence supported the jury’s findings of excessive force and willfulness, and that no impermissible amendment or variance of the indictment occurred. The appellate court affirmed the District Court’s evidentiary rulings and the officer’s convictions. View "USA v. Clark" on Justia Law

The case involved a defendant who was charged with first degree sexual assault of a child, incest with a person under age 18, and tampering with physical evidence. The victim was the defendant’s daughter, who was under 12 years old at the time of the alleged incident. The events in question occurred in the early morning hours, when the child’s mother observed the defendant leaving the children’s bedroom and later questioned her daughter, leading to a disclosure of sexual abuse. The mother examined the child and noticed redness, and the child was subsequently taken to a hospital and a child advocacy center for examination and forensic interviews. The defendant pleaded not guilty, and the case proceeded to a jury trial.The District Court for Douglas County presided over the trial. During the proceedings, the defense objected to certain hearsay testimony and to questions by the prosecution regarding a separate alleged incident of sexual assault. The court overruled some hearsay objections and sustained others, but did not provide limiting instructions or grant a mistrial. The jury found the defendant guilty of first degree sexual assault of a child and incest, but not guilty of tampering with evidence. The court sentenced the defendant to consecutive prison terms within statutory limits. The defendant, represented by new counsel at sentencing, appealed, raising issues including sufficiency of the evidence, evidentiary rulings, prosecutorial misconduct, sentencing, and ineffective assistance of trial counsel.The Nebraska Supreme Court reviewed the case. It held that the evidence was sufficient to support the convictions, as the child’s testimony and corroborating circumstances met the required elements. The court found that any hearsay admitted was cumulative and its admission was harmless beyond a reasonable doubt. Claims of prosecutorial misconduct were reviewed for plain error due to lack of a mistrial motion, and no plain error was found. The sentences were within statutory limits and not an abuse of discretion. The court found the record insufficient to resolve two claims of ineffective assistance of counsel, but rejected the others. The judgment of the district court was affirmed. View "State v. Hagens" on Justia Law

A man was convicted of multiple sexual offenses involving his long-term romantic partner’s daughters. The offenses included three counts against his biological daughter and six counts against his partner’s youngest daughter from a previous relationship. The abuse occurred over several years while the family lived in various residences in the Bay Area. The allegations came to light in 2018 after the mother observed suspicious behavior and questioned her daughters, who then disclosed the abuse. The police were notified, and the children underwent forensic interviews and examinations. The defendant was arrested and charged with several counts, including lewd acts, forcible lewd acts, sexual penetration, and oral copulation with minors under the age of 14 and 10.The case was tried before a jury in the Superior Court of Alameda County. The prosecution presented testimony from the victims, their mother, and expert witnesses on child sexual abuse. The prosecution also introduced evidence of uncharged acts of abuse involving other children in the defendant’s extended family. The defense called character witnesses and challenged the reliability of the victims’ accounts. The jury found the defendant guilty on all but two counts, for which the prosecutor later dismissed the charges after a deadlock. The defendant was sentenced to 54 years to life in prison.On appeal, the California Court of Appeal, First Appellate District, Division Four, reviewed several claims, including alleged errors in jury selection, admission of evidence of uncharged acts, admission of prior statements, prosecutorial misconduct, jury instructions, and expert testimony. The court held that the trial court properly overruled the objection to the prosecution’s peremptory challenge of a Black juror, finding no substantial likelihood that race was a factor. The court also found no abuse of discretion in admitting evidence of uncharged acts, prior statements, or expert testimony, and rejected claims of instructional error and prosecutorial misconduct. The judgment was affirmed. View "People v. Garcia" on Justia Law

The defendant was originally sentenced in 2005 to a 10-year prison term for assault with a deadly weapon, with additional time added for inflicting great bodily injury, personal use of a weapon, and three prior prison commitments. Nearly two decades later, the defendant sought recall and resentencing under Penal Code section 1172.75, which invalidates certain prior prison term enhancements. However, by this time, the defendant was no longer serving the original sentence that included the enhancements; instead, he was incarcerated for offenses committed while in prison, with those sentences running consecutively to the original term.After the California Department of Corrections and Rehabilitation identified the defendant as potentially eligible for relief, the Superior Court of Riverside County examined whether he qualified under section 1172.75. The court found, based on the defendant’s record, that he had completed the sentence containing the prior prison term enhancements and was now serving time solely for in-prison offenses. Relying on People v. Escobedo, the court concluded that section 1172.75 only applies to individuals currently serving a sentence that includes the now-invalidated enhancements, and not to those serving subsequent, separate sentences for in-prison offenses. The court also rejected the defendant’s equal protection argument, finding a rational basis for the legislative distinction.The California Court of Appeal, Fourth Appellate District, Division Two, affirmed the lower court’s decision. The appellate court held that eligibility for resentencing under section 1172.75 is limited to defendants currently serving a sentence that includes a prior prison term enhancement. Because the defendant was serving a sentence for in-prison offenses, not the original judgment with the enhancements, he was ineligible for relief. The court also found no equal protection violation in the statutory scheme. View "People v. McKean" on Justia Law

Three siblings, all under the age of 14, lived with their father across the street from the defendant between 2015 and 2017. During this period, the children frequently played with the defendant’s children. In 2021, after moving in with a legal guardian due to their father’s poor health and subsequent death, the siblings disclosed that the defendant had repeatedly sexually abused them over a prolonged period. The abuse included acts of sexual intercourse, sodomy, and oral copulation, often accompanied by threats involving firearms. The defendant was charged with multiple counts of continuous sexual abuse of a child, sexual intercourse or sodomy with a child 10 years of age or younger, and oral copulation or sexual penetration with a child 10 years of age or younger.A jury in the Lake County Superior Court found the defendant guilty on all nine counts and found true the multiple-victim allegation. The defendant was sentenced to 75 years to life in prison, with sentences on the remaining counts stayed. On appeal to the California Court of Appeal, First Appellate District, Division Three, the defendant argued that Penal Code section 288.5 was unconstitutional under the Sixth Amendment’s jury unanimity requirement as interpreted in Ramos v. Louisiana, and also challenged the jury instructions regarding unanimity.The California Court of Appeal, First Appellate District, Division Three, held that section 288.5 does not violate the Sixth Amendment’s jury unanimity requirement. The court reasoned that the statute requires unanimity as to the continuous-course-of-conduct element, even if jurors may disagree on the specific acts constituting that conduct. The court also found the jury instruction claim forfeited, as the instructions given were accurate and did not affect the defendant’s substantial rights. The judgment was affirmed. View "People v. Hill" on Justia Law

The petitioner, who was previously sentenced to death in Ohio, obtained a conditional writ of habeas corpus from the United States Court of Appeals for the Sixth Circuit, which required the State of Ohio to conduct a new penalty-phase proceeding within 180 days or have the death sentence vacated. The state failed to meet this deadline, even after receiving several extensions due to complications such as judicial recusals, defense preparations, and questions regarding the petitioner’s competency. As a result, the United States District Court for the Northern District of Ohio converted the conditional writ into an unconditional writ, ordering the state to vacate the death sentence and release the petitioner within five business days. The state did not fully comply until nearly three months later, when the state court formally vacated the sentence.After the state’s delayed compliance, the petitioner moved for relief from the unconditional writ, seeking as a sanction an order barring the state from reprosecuting the death penalty. The district court denied this request, finding that although there were significant delays, many were attributable to the petitioner, and the state’s conduct did not rise to the level of bad faith or substantial inequitable conduct that would justify barring reprosecution.On appeal, the United States Court of Appeals for the Sixth Circuit held that it had jurisdiction to review both the unconditional writ and the denial of the Rule 60(b) motion for sanctions, even after the state’s eventual compliance. The court affirmed the district court’s judgment, holding that the delays and procedural complications did not constitute extraordinary circumstances or substantial inequitable conduct warranting a bar on reprosecution of the death penalty. The court also found no abuse of discretion in the district court’s denial of further relief under Rule 60(b). View "Allah-U-Akbar v. Bradshaw" on Justia Law