Justia Criminal Law Opinion Summaries

Curtis Walker, who was 17 years old when he committed murder, was sentenced to life in prison with a parole eligibility date set for 2071, effectively making it a life-without-parole sentence. After serving nearly 30 years, Walker sought postconviction relief, arguing that his sentence violated the Eighth Amendment based on a series of Supreme Court decisions regarding juvenile offenders sentenced to life without parole. Walker's request for a "meaningful opportunity" to demonstrate his rehabilitation was denied by the Wisconsin state courts, prompting him to file a federal habeas corpus petition.The Wisconsin Court of Appeals denied Walker's postconviction motion, holding that his sentence did not violate the Eighth Amendment because the sentencing judge had considered his youth and its attendant circumstances. The Wisconsin Supreme Court denied review. Walker then filed a federal habeas petition, which the district court dismissed as untimely and without merit, concluding that the Wisconsin Court of Appeals did not unreasonably apply federal law.The United States Court of Appeals for the Seventh Circuit reviewed the case and affirmed the district court's denial of habeas relief. The court held that the Wisconsin Court of Appeals did not unreasonably apply Supreme Court precedent, particularly in light of the decisions in Miller v. Alabama, Montgomery v. Louisiana, and Jones v. Mississippi. The Seventh Circuit concluded that the state court's decision was not contrary to or an unreasonable application of clearly established federal law, as the Supreme Court's precedents did not clearly establish a categorical prohibition against sentencing corrigible juvenile offenders to life without parole. View "Walker v Cromwell" on Justia Law

In 1987, Pervis Payne was convicted of two counts of first-degree murder and one count of assault with intent to commit first-degree murder, receiving two death sentences and a thirty-year imprisonment term. The court ordered the sentences to be served consecutively, anticipating potential future commutation of the death sentences to life sentences. Decades later, following a legal pathway established by the Tennessee legislature, Payne was adjudicated intellectually disabled, leading to the vacating of his death sentences and their replacement with life sentences. The trial court also ordered that Payne’s sentences be served concurrently, making him eligible for parole in 2026.The Shelby County Criminal Court adjudicated Payne intellectually disabled and vacated his death sentences, substituting them with life sentences. The court also revisited the consecutive sentencing determination and ordered the sentences to be served concurrently. The State appealed, and the Court of Criminal Appeals affirmed the trial court’s decision, holding that the trial court had discretion to consider the manner of service of the sentences after vacating the death penalty.The Supreme Court of Tennessee reviewed the case and held that the trial court lacked jurisdiction to realign Payne’s sentences. The court affirmed the modification of Payne’s death sentences to life imprisonment but vacated the part of the trial court’s judgment that ordered the sentences to be served concurrently. The court emphasized that once a criminal judgment becomes final, it may not be modified unless a statute or rule authorizes its modification. The court remanded the case to the trial court for further proceedings consistent with its opinion. View "State of Tennessee v. Payne" on Justia Law

Michael Williams was convicted by a Wisconsin jury of reckless homicide and possession of a firearm as a convicted felon. He appealed his convictions to the Wisconsin Court of Appeals, arguing that a jury instruction unconstitutionally lowered the government's burden of proof and that the prosecutor's closing arguments improperly shifted the burden of proof to him. The Wisconsin Court of Appeals affirmed the convictions, and the Wisconsin Supreme Court denied his petition for review.Williams then filed a petition for habeas corpus in the United States District Court for the Eastern District of Wisconsin. The district court held that the state appellate court reasonably applied Supreme Court precedent in concluding that it was not reasonably likely the jury applied the instruction in an unconstitutional manner. The court also held that Williams had not demonstrated that the prosecutor's remarks violated clearly established Supreme Court precedent.On appeal to the United States Court of Appeals for the Seventh Circuit, Williams raised the same two arguments. The Seventh Circuit affirmed the district court's decision. The court held that the Wisconsin Court of Appeals did not unreasonably apply Supreme Court precedent regarding the jury instruction on reasonable doubt. The court also found that the prosecutor's comments during closing arguments did not shift the burden of proof to the defense in a manner that violated due process, especially considering the trial court's curative instructions. The Seventh Circuit concluded that Williams had not shown that the state court's rulings were so lacking in justification as to constitute an unreasonable application of clearly established federal law. View "Williams v Meisner" on Justia Law

Defendants Jerrold Chavarria and Jerry Romero were accused of kidnapping and murdering a woman in Eddy County, New Mexico. They were charged with the federal crime of kidnapping resulting in death under 18 U.S.C. § 1201(a). The indictment claimed that the defendants used a motor vehicle, a Jeep, as an instrumentality of interstate commerce in committing the crime. However, the indictment did not provide details on how the kidnapping affected interstate commerce.The United States District Court for the District of New Mexico dismissed the superseding indictment, ruling that it lacked an adequate nexus to interstate commerce. The court found that the use of a motor vehicle alone, without more, was insufficient to establish federal jurisdiction under the Commerce Clause.The United States Court of Appeals for the Tenth Circuit reviewed the case. The court held that not all motor vehicles are per se instrumentalities of interstate commerce. It emphasized that for an object to be considered an instrumentality of interstate commerce, it must serve the end of commerce. The court found that the government’s indictment was insufficient because it did not allege how the use of the motor vehicle in this case affected interstate commerce. The Tenth Circuit affirmed the district court’s dismissal of the superseding indictment, concluding that the federal kidnapping statute did not apply in this instance due to the lack of a sufficient connection to interstate commerce. View "United States v. Chavarria" on Justia Law

Donald Ferguson was convicted by a jury of sexually abusing his adopted daughter, Jane Doe, under 18 U.S.C. § 2244(a)(5). Ferguson appealed, arguing that the trial court erroneously admitted the first nine and a half minutes of Doe’s forty-five-minute forensic interview. This portion of the interview included rapport-building and rule-explanation segments conducted by NCIS Agent Hannah Gottardi.The United States District Court for the Eastern District of Virginia admitted the entire video recording of the forensic interview, including the first nine and a half minutes, over Ferguson’s objection. The court found the evidence relevant and not unduly prejudicial. Ferguson was subsequently convicted based on the evidence presented, including the forensic interview.The United States Court of Appeals for the Fourth Circuit reviewed the case. The court held that the district court did not abuse its discretion in admitting the first nine and a half minutes of the forensic interview. The appellate court found that the initial segments of the interview were relevant as they demonstrated that the interview followed the National Children’s Advocacy Center protocol, which is designed to elicit accurate recall from the child. The court also determined that the statements made during these segments were not hearsay because they were not offered for the truth of the matter asserted but to show the interview’s adherence to the protocol.The Fourth Circuit concluded that the district court acted within its discretion under Rule 403, finding that the probative value of the evidence was not substantially outweighed by any potential for unfair prejudice. Consequently, the appellate court affirmed Ferguson’s conviction. View "US v. Ferguson" on Justia Law

On December 21, 2022, Oklahoma City Police officers received a tip that Karen Gonzalez, who had an outstanding arrest warrant, was at a Days Inn. Officers surveilled the area and followed a car they believed she entered to a gas station. They confirmed her identity and arrested her. Jonas Tyler, who was near the car, was detained, handcuffed, and placed in a police car. Despite his compliance and lack of suspicion, officers detained him further while waiting for a K-9 unit, which eventually led to the discovery of a firearm and drugs in his car.The United States District Court for the Western District of Oklahoma denied Mr. Tyler's motion to suppress the evidence found in his car, ruling that his continued detention was reasonable. Mr. Tyler then entered a conditional guilty plea to possession of a firearm by a previously convicted felon, reserving his right to appeal the suppression ruling. He was sentenced to 84 months in prison.The United States Court of Appeals for the Tenth Circuit reviewed the case and found that Mr. Tyler's continued detention after the arrest of Ms. Gonzalez was unreasonable and violated his Fourth Amendment rights. The court held that the government did not have a sufficient justification for detaining Mr. Tyler beyond the initial arrest of Ms. Gonzalez, as there was no reasonable suspicion of wrongdoing or dangerousness on his part. Consequently, the court vacated Mr. Tyler's conviction and sentence and remanded the case for further proceedings consistent with their opinion. View "United States v. Tyler" on Justia Law

The case involves the Attorney General's request to empanel a special grand jury to investigate allegations of sexual abuse by clergy within the Catholic Church in New Jersey. The Diocese of Camden challenged the grand jury's authority to issue a presentment on this subject, arguing that such a presentment would not relate to public affairs or conditions as required by law.The trial court denied the Attorney General's request to empanel a special grand jury and found that the anticipated presentment was not authorized by law. The court cited the substantial commitment of time and resources needed to select unbiased grand jurors, the financial hardship on jurors, and the fact that priests are not public officials and the Catholic Church is not a public entity. The court also noted that the presentment would be fundamentally unfair to those accused, as they would not have the same protections as defendants charged by indictment. The Appellate Division summarily affirmed the trial court's judgment.The Supreme Court of New Jersey reviewed the case and reversed the lower courts' decisions. The Court held that it was premature for the trial court to conclude that any potential presentment had to be suppressed, as no grand jury had completed an investigation or issued a presentment. The Court emphasized that the relevant case law and court rule on presentments contemplate the existence of both a grand jury investigation and an actual presentment for an assignment judge to review. The Court found that the State has the right to proceed with its investigation and present evidence before a special grand jury. If the grand jury issues a presentment, the assignment judge should review the report and publish it if it complies with the legal standards outlined by the Court. The Court vacated the trial court's analysis and remanded the matter for further proceedings consistent with its opinion. View "In re the Matter Concerning the State Grand Jury" on Justia Law

Fourteen plaintiffs, including pilots, a physician, a nurse, and an attorney, were required to undergo alcohol testing to maintain their employment and professional licenses. The tests, developed by United States Drug Testing Laboratories, Inc. (USDTL), indicated positive results for alcohol consumption, leading to significant professional harm. The plaintiffs alleged that the tests were unreliable and sued USDTL and its officers under the Racketeer Influenced and Corrupt Organizations Act (RICO) and state law. They also sued Choice Labs Services (CLS) and its owners, who provided the tests to the administrators.The plaintiffs initially filed suit in the Southern District of Florida, asserting claims for fraud and negligence. The district court dismissed the case without prejudice, finding the complaint insufficient. The plaintiffs then filed a second amended complaint, adding CLS as defendants. The case was transferred to the Northern District of Illinois, where the district court dismissed the RICO claims under Rule 12(b)(6) and denied supplemental jurisdiction over the state law claims. The plaintiffs' motion to alter or amend the judgment was also denied.The United States Court of Appeals for the Seventh Circuit reviewed the case de novo and affirmed the district court's decision. The court held that the plaintiffs failed to establish proximate causation for their RICO claims, as they did not adequately allege a direct link between USDTL's alleged misrepresentations and their professional injuries. The court also found that the plaintiffs did not meet the heightened pleading requirements for fraud under Rule 9(b). Consequently, the RICO claims were dismissed with prejudice, and the state law claims were dismissed without prejudice. View "Ratfield v United States Drug Testing Laboratories, Inc." on Justia Law

A 15-year-old girl, S.W., left her home in Anoka County, Minnesota, without permission to stay with her mother’s cousin, A.G., in Wisconsin, where A.G. lived with the defendant, Paulson. After using methamphetamine together, Paulson assaulted A.G., took S.W. to his family’s property in Stacy, Minnesota, and kept her there for two days, during which he threatened her, provided her with drugs, and sexually assaulted her. S.W. was eventually recovered in Anoka County, where she reported the kidnapping and assaults to police.Paulson was initially charged in Anoka County District Court with first- and second-degree criminal sexual conduct. He moved to dismiss, arguing the offenses occurred in Isanti County, not Anoka County. The district court denied the motion, finding venue proper in Anoka County under Minnesota Statutes section 627.15, since S.W. was found there. The State later amended the complaint to add a kidnapping charge, to which Paulson entered an Alford plea. He did not challenge venue for the new charge. The district court accepted the plea and imposed sentence. On appeal, Paulson argued that his plea was invalid because the factual basis did not establish that venue was proper in Anoka County as required by Minnesota Statutes section 627.01. The Minnesota Court of Appeals rejected this argument, holding that venue is not an element of the offense.The Minnesota Supreme Court reviewed whether the statutory venue requirement is an element of the offense for purposes of the accuracy requirement of a guilty plea. The court held that the venue requirement in section 627.01 is not an element of the offense, and therefore, the factual basis for Paulson’s guilty plea was sufficient even though it did not establish venue. The decision of the court of appeals was affirmed. View "State of Minnesota vs. Paulson" on Justia Law

Terry Eugene Ross Jr. was charged with multiple crimes, including domestic violence against his wife A.R., sexual abuse of his stepdaughters H.L. and D.L., and violations of protection orders. The incidents occurred between January and August 2019, with Ross allegedly exerting control and committing acts of violence and sexual abuse within the household. The State of Kansas consolidated five separate cases against Ross for trial, arguing that the crimes were part of a common scheme or plan to dominate and control the women in his household.The Sedgwick District Court granted the State's motion to consolidate the cases, finding that the crimes were of the same or similar character and part of a common scheme or plan. The court also ruled that the probative value of consolidating the cases outweighed any potential prejudice to Ross. Ross was convicted on most charges, but acquitted on a few, including aggravated assault and unlawful discharge of a firearm. He was sentenced to three consecutive life sentences plus additional time for other charges.The Kansas Court of Appeals reversed Ross' convictions, finding errors in the district court's decision to consolidate the cases and identifying prosecutorial error. The panel also concluded that the jury's convictions on two alternatively charged counts warranted reversal. The State petitioned for review, and Ross conditionally cross-petitioned.The Kansas Supreme Court held that the district court did not err in consolidating the cases, as the crimes were part of a common scheme or plan. The court also found no prosecutorial error in the opening statements and concluded that Ross failed to preserve a challenge to the inadvertent publication of an unredacted 911 call. The cumulative error doctrine did not apply as no errors were found. The Supreme Court reversed the Court of Appeals' decision, except for the two convictions on counts two and three of 19-CR-2036, which were left undisturbed and remanded for further proceedings. View "State v. Ross " on Justia Law