Justia Criminal Law Opinion Summaries

The defendant pled guilty in 2016 to conspiracy to possess with intent to distribute controlled substances, receiving a sentence of 160 months based on his criminal history and offense level. In 2023, a retroactive amendment to the Sentencing Guidelines reduced his criminal history category, lowering his guideline range. The defendant, through appointed counsel, and the government stipulated to a new recommended sentence of 144 months, which the district court imposed.After resentencing, the defendant filed a pro se motion for reconsideration, asserting that his counsel had agreed to the stipulation without his knowledge or consent and that he wished to argue for a lower sentence. The United States District Court for the Eastern District of Michigan denied the motion, reasoning that because the defendant was represented by counsel, his pro se filing constituted improper hybrid representation. The court instructed that any motion for reconsideration should be filed through counsel.On appeal, the United States Court of Appeals for the Sixth Circuit held that when a defendant raises a specific and serious allegation that counsel acted without his knowledge or against his wishes on a fundamental matter, the district court is obligated to inquire into the nature of the attorney-client relationship, regardless of whether the defendant used “magic words” or filed through counsel. The Sixth Circuit found that the district court erred by denying the motion solely on the basis of hybrid representation without conducting such an inquiry. The court vacated the district court’s judgment on the motion for reconsideration and remanded for further proceedings, instructing the district court to determine whether the defendant wishes to dismiss his counsel and whether he is entitled to do so, and then to address the merits of his motion. View "United States v. Riley" on Justia Law

In 2009, a defendant was sentenced to an indeterminate term of 28 years to life under California’s original Three Strikes law after his third felony conviction, which was not classified as serious or violent. He also received three one-year enhancements for prior prison terms. In 2012, California voters passed the Three Strikes Reform Act (Proposition 36), which limited indeterminate life sentences to cases where the third strike was serious or violent, and allowed those serving indeterminate sentences for nonserious, nonviolent felonies to petition for resentencing, subject to a discretionary public safety determination by the court.After the Reform Act, the defendant petitioned for resentencing under section 1170.126, but the Santa Barbara County Superior Court denied the petition, finding his release would pose an unreasonable risk to public safety. The California Court of Appeal affirmed this decision. In 2021, the Legislature enacted Senate Bill No. 483, which retroactively invalidated certain prior prison term enhancements and required courts to recall and resentence affected defendants, applying any changes in law that reduce sentences. The defendant sought resentencing under this new law, and the trial court resentenced him to a determinate eight-year term. The Santa Barbara District Attorney challenged this, arguing that the new law unconstitutionally amended the voter-enacted Reform Act by bypassing its public safety requirement. The Court of Appeal agreed and reversed the trial court’s decision.The Supreme Court of California reviewed whether Penal Code section 1172.75, as applied, unconstitutionally amended the Reform Act. The Court held that section 1172.75 must be interpreted to incorporate the Reform Act’s discretionary public safety determination for nonserious, nonviolent third strike offenders seeking resentencing. This interpretation harmonizes the statutes and avoids constitutional conflict, allowing the revised penalty provisions to apply only if the court finds resentencing does not pose an unreasonable risk to public safety. The Court reversed the Court of Appeal and remanded for further proceedings consistent with this holding. View "P. v. Guevara" on Justia Law

The defendant was charged with murder and contributing to the delinquency of a minor after allegedly killing his wife in their home while their two young children were present. Before trial, the prosecution requested that the children be allowed to testify remotely, arguing that testifying in the defendant’s presence would cause them significant emotional distress and impair their ability to communicate. The district court held hearings, received testimony from mental health professionals who had treated the children, and ultimately granted the State’s motion, finding that remote testimony was necessary to prevent serious emotional trauma to the children.The District Court of Cass County, East Central Judicial District, presided over the case. The defendant pleaded guilty to the charge of contributing to the deprivation of a minor, and the murder charge proceeded to trial. The court instructed the jury that the children’s remote testimony was permissible by law and should not influence their deliberations. The children testified via two-way electronic communication, and the jury found the defendant guilty of murder. The court entered a judgment sentencing him to life imprisonment without parole. The defendant appealed, arguing that the district court failed to make the findings required by statute for remote testimony and that his constitutional right to confront witnesses was violated.The Supreme Court of North Dakota reviewed the case. It held that the district court made the necessary findings under North Dakota Century Code § 31-04-04.2(1), specifically that testifying in the defendant’s presence would likely cause the children serious emotional distress or trauma impacting their ability to communicate. The Supreme Court found these findings were supported by the evidence and not contrary to the manifest weight of the evidence. The court concluded that the defendant’s confrontation rights were not violated and affirmed the criminal judgment. View "State v. Moen" on Justia Law

Juan Javier Oquendo was charged with first-degree murder following the fatal shooting of James Cason outside a bar in Pinellas County, Florida. On the night of the incident, Oquendo interacted with several individuals, including his sister and a security guard, before an altercation occurred with Cason near Cason’s car. Witnesses provided conflicting accounts regarding whether Cason or Oquendo produced a gun and how the shooting transpired. Physical evidence indicated multiple shots were fired, and Cason died from a gunshot wound to the head. After the incident, Oquendo fled and later admitted to another individual that he had shot someone. At trial, Oquendo claimed the gun discharged accidentally during a struggle, and the jury was instructed on self-defense.The Circuit Court for Pinellas County denied Oquendo’s request to present expert testimony from a psychologist regarding his post-traumatic stress disorder (PTSD), finding the evidence irrelevant to the self-defense claim and potentially confusing to the jury as diminished capacity evidence. The jury acquitted Oquendo of first-degree murder but convicted him of manslaughter with a firearm. The Second District Court of Appeal affirmed the conviction, holding that PTSD evidence was categorically irrelevant to self-defense under Florida’s objective reasonable person standard, and certified conflict with the First District Court of Appeal’s decision in State v. Mizell, which had allowed limited PTSD evidence in support of self-defense.The Supreme Court of Florida reviewed the case to resolve the conflict. It held that Florida’s self-defense standard contains both a subjective component—what the defendant actually believed—and an objective component—what a reasonably prudent person would believe. PTSD evidence may be relevant to the subjective component but not the objective one. Nevertheless, the Court found no reversible error in excluding the PTSD testimony in Oquendo’s case and approved the Second District’s affirmance of his conviction. View "Oquendo v. State of Florida" on Justia Law

Jonathan Guthmiller was convicted of failing to register as a sexual offender, a requirement stemming from his 2017 guilty plea to luring a minor by computer. Under North Dakota law, he was obligated to register twice yearly and to update his registration within three days of any change in his phone number. In September 2024, Guthmiller was charged for failing to register a valid phone number and for not completing his August 2024 registration.The case was tried in the District Court of Grand Forks County, Northeast Central Judicial District. Before trial, the State proposed jury instructions that did not include the location of the offense as an essential element, citing State v. Samaniego. Guthmiller did not submit alternative instructions or object to the State’s proposal. At a status conference, the court explained the instructions to Guthmiller, who confirmed his understanding and explicitly stated he had no objection. Guthmiller represented himself at trial and did not move for acquittal. The jury found him guilty.On appeal to the Supreme Court of the State of North Dakota, Guthmiller argued there was insufficient evidence to support his conviction, specifically contending the State failed to prove the conduct occurred in Grand Forks County or North Dakota. He also challenged the jury instructions for omitting the location element. The Supreme Court held that Guthmiller had waived any objection to the jury instructions by affirmatively agreeing to them at trial. As a result, the instructions became the law of the case, and the State was not required to prove the location of the offense. The Court found sufficient evidence supported the jury’s verdict and affirmed the criminal judgment. View "State v. Guthmiller" on Justia Law

On December 25, 2022, Nathaniel Fort and his brother, Tarus Walker, went to Aaron Bruce’s apartment to confront him over an alleged assault involving Walker’s child. Walker was armed with an AK-47 rifle, and Fort carried two .40-caliber handguns. After Bruce left his apartment and joined his cousin, Patrick Ross, to discuss the matter, Walker shot Bruce, who fell to the ground. Fort then fired multiple shots into Bruce as he lay on the ground. The two men fled the scene in a vehicle matching the description of Fort’s mother’s car. Police recovered .40-caliber shell casings and bullets near Bruce’s body, and Bruce died at the scene from multiple gunshot wounds.The case was tried in the Miller County Circuit Court. During trial, the prosecution sought to admit Bruce’s autopsy report after the medical examiner who performed the autopsy became unavailable due to illness. Fort objected, arguing that the report required proper attestation and a supporting witness for admission. The circuit court overruled the objection, finding that Fort had waived his right to cross-examine by not subpoenaing a medical examiner or filing a notice of intent to cross-examine. The autopsy report was admitted, and Fort was convicted of capital murder and sentenced to life imprisonment.On appeal to the Supreme Court of Arkansas, Fort challenged the admission of the autopsy report, the denial of his right of allocution, and the sufficiency of the prosecutor’s short report of circumstances. The Supreme Court of Arkansas held that the circuit court erred in admitting the autopsy report without proper attestation, but found the error harmless due to overwhelming evidence of guilt and the cumulative nature of the report. The court also held that Fort’s allocution and report objections were unpreserved for appeal. The conviction and sentence were affirmed. View "FORT V. STATE OF ARKANSAS" on Justia Law

A police officer responded to a report of a car accident in a residential area during the early morning hours and found a vehicle partially in a yard, facing the wrong direction. The officer approached the vehicle and saw Ambreia Washington in the driver’s seat, with a handgun visible on the front passenger seat. After asking Washington to exit the vehicle, the officer inquired whether Washington was a convicted felon, to which Washington replied affirmatively. When Washington attempted to flee, the officer used a taser and placed him under arrest, seizing the handgun. Washington was indicted for unlawful possession of a firearm by a convicted felon and other charges.Washington moved to suppress both the handgun and his statement regarding his felony status. The Circuit Court for Madison County suppressed the statement due to a Miranda violation but denied the motion to suppress the handgun, finding it was properly seized under the plain view doctrine. At trial, Washington was convicted by a jury. On appeal, the Tennessee Court of Criminal Appeals affirmed the trial court’s rulings, concluding that the officer’s actions were justified under the community caretaking doctrine and that the seizure of the handgun was permissible under the plain view doctrine.The Supreme Court of Tennessee reviewed whether the officer’s warrantless seizure of the firearm was lawful. The court held that the seizure was constitutionally permissible under the plain view doctrine, even though the officer’s probable cause to seize the gun was based on Washington’s unwarned but voluntary admission of his felony status. The court clarified that such nontestimonial evidence derived from a voluntary but un-Mirandized statement need not be suppressed absent coercion. The judgment of the Court of Criminal Appeals was affirmed. View "State v. Washington" on Justia Law

Three individuals were tried and convicted following a three-week jury trial for their involvement in a violent criminal enterprise. The evidence showed that they were members of a gang operating in northern Virginia and participated in two attempted murders in 2019. One victim was lured into a car, attacked, and left for dead, while another was targeted after surveillance and shot. The defendants played various roles, including driving, surveillance, and assisting in evasion from law enforcement. The charges included racketeering conspiracy, conspiracy to commit murder, drug distribution conspiracy, and, for some, attempted murder, assault with a dangerous weapon, and firearms offenses.The United States District Court for the Eastern District of Virginia presided over the trial. During the proceedings, issues arose regarding the quality of interpretation provided by a court-appointed interpreter, leading the defendants to move for a mistrial. The district court conducted a hearing, found the interpretation errors to be limited and not material, and denied the motion for mistrial. After the trial, the government disclosed unrelated official misconduct by its expert witness on gangs, prompting the defendants to move for a new trial. The district court denied this motion, finding the new evidence was merely impeaching and not material, given the overwhelming evidence of guilt.The United States Court of Appeals for the Fourth Circuit reviewed the case. It held that the interpretation errors did not rise to the level of a constitutional or structural error, as they were isolated and did not render the trial fundamentally unfair. The court also held that the post-trial disclosure regarding the government’s expert witness did not warrant a new trial under Rule 33 or Brady, as it was not material and would not have likely produced a different result. The Fourth Circuit affirmed the district court’s judgment. View "US v. Sandoval" on Justia Law

A federal inmate serving a 210-month sentence challenged the method used by the Federal Bureau of Prisons (BOP) to calculate his good conduct time credits under 18 U.S.C. § 3624(b)(1), as amended by the First Step Act of 2018. The inmate argued that, following the amendments, he should receive a full 54 days of good conduct time credit for the last six months of his sentence, rather than a prorated amount. The BOP, however, interpreted the amended statute to require prorating the credit for any partial year, resulting in the inmate receiving 26 days of credit for the final six months instead of 54.The United States District Court for the District of New Jersey denied the inmate’s habeas petition. The court found that the plain language of the amended statute allowed for proration of good conduct time credits for partial years. As an alternative basis, the District Court also relied on Chevron deference to uphold the BOP’s interpretation. The court rejected the inmate’s additional claims under the Administrative Procedure Act (APA) and the Due Process Clause, finding them either precluded by statute or inapplicable to the rulemaking context.On appeal, the United States Court of Appeals for the Third Circuit reviewed the statutory interpretation de novo. The Third Circuit affirmed the District Court’s judgment, holding that the First Step Act’s amendments, while deleting the word “prorated,” introduced language (“for each year”) that sets a rate of 54 days per year, thereby requiring proration for any partial year. The court concluded that the statute’s natural reading supports the BOP’s method of prorating credits for the last portion of a sentence. The Third Circuit also rejected the inmate’s constitutional and APA-based arguments, and found no basis for applying the rule of lenity. View "Thieme v. Warden Fort Dix FCI" on Justia Law

Edwin Diaz was stopped by law enforcement in Ida Grove, Iowa, after Deputy Clausen observed his truck parked with only one working headlight, broken taillights, and impeding traffic. Upon approaching the vehicle, Clausen smelled marijuana and saw Diaz drop an item later identified as methamphetamine. Diaz and his passenger, Mikaela Breen, were arrested and charged with state drug offenses. Days later, Breen reported to police that Diaz had coerced her into signing a statement taking responsibility for the drugs found in the truck. Based on Breen’s account and Diaz’s criminal history, law enforcement obtained a warrant to search Diaz’s residence, where they found drugs, paraphernalia, and a firearm.The United States District Court for the Northern District of Iowa reviewed Diaz’s motion to suppress evidence from both the truck and home searches. The magistrate judge recommended denying the motion, finding that the truck search was lawful due to probable cause from observed traffic violations and the smell of marijuana, and that the good faith exception applied to the home search despite questions about the warrant’s nexus to the residence. The district judge agreed that the truck search was justified by probable cause and that the good faith exception protected the home search evidence, even though the warrant affidavit did not establish a sufficient nexus between the drugs and Diaz’s home.On appeal, the United States Court of Appeals for the Eighth Circuit affirmed the district court’s denial of the suppression motion. The court held that the initial encounter with Diaz was supported by reasonable suspicion and probable cause due to multiple traffic violations and the odor of marijuana, justifying the truck search. For the home search, the court found that the Leon good faith exception applied because it was not entirely unreasonable for officers to believe that a drug dealer would store contraband at his residence, even if the warrant affidavit lacked a direct nexus. The judgment was affirmed. View "United States v. Diaz" on Justia Law