Justia Criminal Law Opinion Summaries

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

Joshua Martinez was charged in two separate cases with serious offenses, including attempted murder, reckless endangerment, terrorizing, fleeing from law enforcement, violation of a domestic violence protection order, unlawful firearm possession, and other related crimes. The cases were consolidated and proceeded to a seven-day jury trial, where twelve jurors and two alternates were sworn in. After the first day of trial, Juror 9 was observed interacting with Jacob Martinez, a relative of the defendant. Upon questioning, Juror 9 disclosed he only learned of the familial relationship after speaking with Jacob Martinez. Despite Juror 9’s assurance of impartiality, the district court dismissed him, citing concerns about the interaction, and replaced him with an alternate juror.The District Court of Williams County, Northwest Judicial District, presided over the consolidated trial. Following the jury’s verdict, Martinez was convicted on all counts except one of reckless endangerment. Martinez objected to the removal of Juror 9, arguing that the substitution violated his constitutional rights and exceeded the court’s authority under North Dakota Rule of Criminal Procedure 24(c)(1).On appeal, the Supreme Court of North Dakota reviewed whether the district court’s decision to replace Juror 9 constituted an abuse of discretion or violated the Double Jeopardy Clause. The Supreme Court held that substituting a properly qualified alternate juror did not implicate double jeopardy, as it did not terminate the original jeopardy. The court further held that the district court’s expressed concerns regarding Juror 9’s impartiality constituted a sufficient basis for dismissal, and that the court did not abuse its discretion in replacing Juror 9 with an alternate. Accordingly, the Supreme Court of North Dakota affirmed the criminal judgments against Martinez. View "State v. Martinez" on Justia Law

In 2010, a woman was found dead in her Jacksonville, Florida apartment, having been stabbed approximately ninety times. The investigation led law enforcement to question the defendant, who initially denied involvement but ultimately confessed to the killing and to taking items from the apartment. He was charged with first-degree murder. At trial in Duval County, a jury found him guilty, and after a penalty-phase proceeding where the defendant declined to present additional mitigating evidence, the jury unanimously recommended a death sentence. The trial court imposed the death penalty, finding the aggravating factors outweighed the mitigating circumstances.The Florida Supreme Court previously affirmed his conviction and sentence on direct appeal. Subsequent challenges included an initial postconviction motion, a state habeas petition, and a first successive postconviction motion, all of which were denied. While the first successive motion was pending, the defendant filed a second successive postconviction motion in the state circuit court, raising new constitutional claims related to the representativeness of his jury. He relied on a recent academic study to argue that his jury was not drawn from a fair cross-section of the community. The circuit court summarily denied the motion as untimely and meritless.The Supreme Court of Florida reviewed the appeal from the circuit court’s summary denial. The court held that the claims were untimely under rule 3.851, as the academic study did not constitute newly discovered evidence. Additionally, the claims were procedurally barred because they could have been raised earlier. The court also found the Sixth, Eighth, and state constitutional claims to be legally insufficient, clarifying that the fair cross-section requirement applies to the jury pool, not the petit jury. The denial of postconviction relief was affirmed. View "David Kelsey Sparre v. State of Florida" on Justia Law

Geoffrey P. Seymore was charged with three methamphetamine-related offenses in De Kalb County, Illinois. Upon his initial court appearance, he was granted pretrial release with several conditions, including electronic monitoring. The day after release, Seymore traveled outside his residence to multiple locations, prompting the De Kalb County Sheriff’s Office to file a report alleging he violated the electronic monitoring condition. The State subsequently petitioned for sanctions, requesting 30 days’ imprisonment in the county jail for the violation. The trial court held a hearing, found the violation proven by clear and convincing evidence, and ordered Seymore to serve 30 days in jail, specifying that no good-behavior credit would apply.Following this, Seymore’s public defender filed a motion seeking good-behavior credit under section 3 of the County Jail Good Behavior Allowance Act for the 30-day jail sanction, but the De Kalb County Circuit Court denied the motion. Seymore appealed, and the Appellate Court of Illinois, Second District, reversed the trial court’s decision. The appellate court held that good-conduct credit should apply to Seymore’s jail sanction and vacated the trial court’s order on that point. The appellate court also found jurisdiction to hear the appeal, relying on Illinois Supreme Court Rule 604(h)(1), and determined the issue was not moot due to its public importance and likelihood of recurrence.The Supreme Court of the State of Illinois reviewed the case. It held that the 30-day jail sanction imposed for violation of a pretrial release condition was not a "sentence" under section 3 of the Behavior Allowance Act, and thus, Seymore was not entitled to good-conduct credit against that sanction. The court determined that only sentences, not sanctions, qualify for such credit under the Act. Accordingly, the Supreme Court reversed the appellate court’s judgment and affirmed the circuit court’s decision. View "People v. Seymore" on Justia Law

In October 2021, a Florida attorney, Ross, held a trust account at Regions Bank that received a $29.6 million wire transfer, the result of a business email compromise fraud perpetrated on a company called Phoenix. Most of the funds were rapidly transferred out of the account, with some recalled by the bank. Federal authorities seized approximately $4.9 million remaining or recovered from the account and initiated a civil forfeiture action, alleging the funds were proceeds of fraud or involved in money laundering.The United States District Court for the Northern District of New York oversaw the initial proceedings. Ross filed a verified claim to $1.21 million of the seized funds, asserting they were legitimate client funds or proceeds from his home sale, but made no claim to the remaining $3.69 million. Another claimant, Phoenix, also asserted interest in the $1.21 million. The district court entered default judgment forfeiting the unclaimed $3.69 million to the government, dismissed without prejudice the forfeiture proceedings as to the $1.21 million, and issued a certificate of reasonable cause for the seizure. It denied Ross’s subsequent motion for attorney fees, costs, and interest under CAFRA, finding he did not “substantially prevail,” and denied reconsideration.On appeal, the United States Court of Appeals for the Second Circuit held that Ross lacked standing to contest the forfeiture of the $3.69 million because he had not filed a claim as to those funds. The court rejected Ross’s due process challenge to the stay of proceedings, finding the delay reasonable, and upheld the denial of attorney fees, costs, and interest, concluding that dismissal without prejudice did not make Ross a prevailing party under CAFRA. The court also found no abuse of discretion in dismissing the forfeiture action without prejudice. However, the Second Circuit vacated the issuance of a certificate of reasonable cause, as no judgment for Ross had been entered. All other aspects of the district court’s judgments were affirmed. View "United States v. Ross" on Justia Law

Elwood Jones was convicted by a Hamilton County jury of the aggravated felony murder, aggravated burglary, and aggravated robbery of Rhoda Nathan, and sentenced to death. At trial, evidence included the discovery of a pendant similar to Nathan’s in Jones’s vehicle and a hand injury Jones sustained on the day of the murder, which became infected with a bacteria consistent with a fist-to-mouth injury. Nathan’s tooth had been knocked out during the assault. Jones’s convictions and sentence were affirmed on direct appeal and postconviction relief was denied, including claims that the State suppressed material evidence in violation of Brady v. Maryland. Subsequent efforts for federal habeas corpus relief were also unsuccessful.In 2019, Jones moved for a new trial, citing newly discovered evidence and prosecutorial misconduct. The trial court granted him leave and, after an evidentiary hearing, concluded that the State had suppressed material evidence about an alternate suspect and about the uniqueness of Nathan’s pendant. The court also found newly discovered scientific evidence warranted a new trial. The State sought leave to appeal this decision to the First District Court of Appeals, challenging only the Brady violation findings. The appellate court denied leave, reasoning that because the State did not challenge the independent ground of newly discovered scientific evidence, any appeal would be futile.The Supreme Court of Ohio reviewed the case to determine whether the appellate court applied the correct legal standard in ruling on the State’s motion for leave to appeal. The Supreme Court held that the appellate court erred by failing to determine whether the State had shown a high enough probability of trial-court error to warrant a discretionary appeal, as required by App.R. 5(C). The judgment denying leave to appeal was reversed, and the case was remanded for the appellate court to apply the proper standard. View "State v. Jones" on Justia Law

The defendant was convicted, along with a codefendant, of murder in the first degree by extreme atrocity or cruelty after a joint jury trial in 1984. The killing occurred during a fight, and both men received mandatory sentences of life without parole. More than thirty years later, the defendant moved for a new trial, arguing that his trial counsel ignored his repeated requests to seek a plea bargain for a lesser charge, specifically murder in the second degree, which carries the possibility of parole. The defendant claimed he did not learn until 2016 that his attorney had not pursued plea negotiations and that the prosecutor might have been open to a plea if both defendants agreed.After the original convictions were affirmed by the Supreme Judicial Court under plenary review, the codefendant separately moved for a new trial, asserting ineffective assistance in plea negotiations. The Superior Court judge held evidentiary hearings on both the codefendant’s and the defendant’s motions. The judge found that neither attorney had secured or pursued a pretrial plea to murder in the second degree, and that the prosecutor would only have considered such a plea if both defendants agreed. Since this circumstance never arose before trial, the judge denied both motions, finding the arguments were speculative.On appeal, the Supreme Judicial Court of Massachusetts considered whether ineffective assistance may be found when counsel fails to pursue a reasonable plea negotiation at the defendant’s request. The court held that such a claim requires a showing that counsel’s failure was unreasonable and resulted in prejudice—specifically, a reasonable probability that the prosecutor and judge would have accepted the plea, and that the defendant suffered a more severe outcome by going to trial. The court affirmed the denial of the defendant’s motion for a new trial, concluding that there was no reasonable probability a stand-alone plea would have been accepted by the prosecutor. View "Commonwealth v. Mosso" on Justia Law

A man was charged with attempted first-degree premeditated murder and unlawful possession of a firearm following a shooting in Duluth. The victim could not identify the shooter, and evidence at the scene included two guns and DNA samples. Investigators initially obtained a search warrant for DNA samples from the suspect, but after the validity of that warrant was challenged in a co-defendant’s case, the State agreed not to use any evidence obtained from it. Instead, the State sought and received a court order under a Minnesota procedural rule to collect a buccal swab (cheek swab) from the defendant for DNA analysis. This DNA evidence, along with recorded jail calls and texts from an alleged accomplice, was presented at trial. The defendant was convicted by a jury and sentenced to prison.The Minnesota Court of Appeals reversed the convictions, holding that the warrantless collection of the buccal swab violated constitutional protections against unreasonable searches and seizures, and that this error was not harmless beyond a reasonable doubt. The court also held that the defendant was not entitled to a jury instruction requiring corroboration of accomplice testimony, because the accomplice’s statements were not made under oath.Upon review, the Minnesota Supreme Court agreed with the appellate court. It held that collecting a buccal swab for DNA analysis without a warrant or a valid exception constitutes an unreasonable search under both the United States and Minnesota Constitutions. The court rejected arguments that the procedural rule or a court order could replace a warrant, and found no applicable exception to the exclusionary rule. The court also clarified that the statutory term “testimony” in Minnesota’s accomplice-corroboration statute means only statements made under oath. The Supreme Court affirmed the reversal of the convictions and remanded for a new trial. View "State of Minnesota vs. Steeprock" on Justia Law

Petitioner was charged with multiple counts, including murder and attempted murder, arising from an alleged retaliatory shooting involving the “Mongolian Boys Society” gang. He was originally arraigned on a felony complaint in February 2020 and entered a general time waiver for his preliminary hearing. In May 2021, the prosecution amended the complaint to change the nature of certain firearm enhancements; petitioner was arraigned on the amended complaint the same day and agreed to a limited time waiver for the preliminary hearing until August 16, 2021, plus ten court days. The preliminary hearing was ultimately delayed several times due to requests for continuances, discovery issues, and pandemic-related quarantine measures, despite petitioner’s repeated objections to further continuances.The Superior Court of Fresno County held the preliminary hearing in November 2021, outside the period covered by petitioner’s limited waiver on the amended complaint, and subsequently held petitioner to answer on all charges. After the information was filed and the prosecution indicated intent to seek the death penalty, petitioner moved to set aside the information, initially without raising the timeliness issue. Later, he supplemented his motion to argue that the delay violated his right to a speedy preliminary hearing under Penal Code section 859b. The superior court denied the motion. Petitioner then sought writ relief, which was initially denied by the California Court of Appeal, but the California Supreme Court directed the appellate court to reconsider whether petitioner’s speedy preliminary hearing rights were violated.Upon review, the California Court of Appeal, Fifth Appellate District, held that while general time waivers for preliminary hearings under section 859b are irrevocable, a new 60-day period commences upon arraignment on an amended complaint unless expressly waived. Because petitioner did not enter a general time waiver at the second arraignment, and the preliminary hearing was held beyond the statutory time limit, the court granted relief and ordered the information set aside and the complaint dismissed as to petitioner. View "Lee v. Superior Ct." on Justia Law

Christopher Arthur was investigated after founding a business that sold military gear and later provided training and manuals on tactics including the use of explosives. The FBI became involved after a customer, Joshua Blessed, died in a shootout and was found to possess pipe bombs and Arthur’s manuals. Subsequently, an undercover informant, “Buckshot,” sought training from Arthur, who instructed him on fortifying his home and making explosive devices, knowing Buckshot claimed he wanted to use such tactics against federal agents. Arthur was arrested in January 2022 and a search of his home revealed illegal firearms and improvised explosives.A grand jury in the United States District Court for the Eastern District of North Carolina indicted Arthur under 18 U.S.C. § 842(p)(2)(B) for teaching explosives use with knowledge of criminal intent, and on additional firearms and explosives charges. Arthur moved to dismiss the primary count, arguing the statute was facially overbroad under the First Amendment. The district court denied the motion, finding the statute’s knowledge requirement limited its scope to conduct integral to criminal acts, not protected speech. After a three-day trial, the jury found Arthur guilty on all counts. At sentencing, the court applied the U.S.S.G. § 3A1.4 terrorism enhancement, increasing his guidelines range, and sentenced Arthur to a total of 300 months’ imprisonment.The United States Court of Appeals for the Fourth Circuit reviewed the case. It held that 18 U.S.C. § 842(p)(2)(B) is not unconstitutionally overbroad, concluding that the statute targets speech integral to criminal conduct and does not criminalize a substantial amount of protected expressive activity. The Fourth Circuit also found no reversible error in applying the terrorism enhancement, and determined any alleged guidelines error was harmless given the district court’s alternative sentencing rationale. The judgment of the district court was affirmed. View "US v. Arthur" on Justia Law