Justia Criminal Law Opinion Summaries

On November 4, 2024, an individual went to his stepchild’s elementary school to speak with the principal about the child’s recent suspension from bus privileges. During and after this meeting, his behavior—raising his voice, pushing a garbage can into a door, forcefully exiting the building, yelling obscenities, and making obscene gestures in the presence of children—alarmed the principal, a school counselor, and a paraprofessional. Each testified that his actions caused them alarm. He was later charged with disorderly conduct under North Dakota law.The case proceeded to a bench trial in the District Court of Richland County, Southeast Judicial District. The defendant waived his right to a jury trial. The district court found, based on testimony and the totality of the conduct, that the defendant’s actions—including using obscene language, physical agitation, and reckless driving in the school parking lot—constituted tumultuous behavior that reasonably alarmed those present. The court found the statutory elements of disorderly conduct were proven beyond a reasonable doubt and entered a criminal judgment of conviction. The defendant appealed.The Supreme Court of North Dakota reviewed the conviction. The defendant argued that his conduct was constitutionally protected as an exercise of parental rights and that the evidence was insufficient. The Supreme Court held that because the defendant did not raise constitutional claims at trial or argue obvious error on appeal, those arguments would not be addressed. Applying the standard of viewing evidence in the light most favorable to the verdict, the court found that there was sufficient evidence that the defendant acted with at least reckless disregard as to whether his behavior would alarm others and that his conduct was tumultuous. The Supreme Court of North Dakota affirmed the conviction for disorderly conduct. View "State v. Vetter" on Justia Law

The defendant was charged with several offenses after a violent confrontation with a 20-year-old escort in his Queens home, leading to a police investigation that uncovered weapons, ammunition, forgery devices, and other items on the premises. During the jury trial, an alternate juror replaced a dismissed juror, leaving no further alternates. After the jury began deliberations, the foreperson reported an encounter outside his home with a man acting "on behalf of" the defendant, who provided court documents and claimed the defendant’s innocence. The foreperson, shaken by the incident, felt unable to remain impartial and was discharged from the jury.The Supreme Court, Queens County, held a hearing and found by clear and convincing evidence that the defendant orchestrated the confrontation with the foreperson, including feigning illness to leave court early. The court determined that this egregious misconduct was intended to improperly influence the jury. With no alternates available, the court, relying on forfeiture principles from prior cases, concluded the defendant forfeited his constitutional right to a jury of 12, and proceeded with 11 jurors. The 11-person jury found the defendant guilty on some counts and acquitted him on others.The Appellate Division affirmed the conviction, holding that the defendant’s "egregious" misconduct warranted forfeiture of the right to a 12-person jury. A dissenting Justice argued that such forfeiture should only occur in extreme circumstances, analogizing the right to a jury of 12 to the right to counsel. Upon review, the New York Court of Appeals held that a defendant who engages in egregious conduct affecting a sworn juror after deliberations begin, resulting in discharge and no alternates remaining, forfeits the right to a jury of 12. The court affirmed the trial court’s exercise of discretion in proceeding to verdict with 11 jurors. View "People v Sargeant" on Justia Law

In two separate incidents, young children under the care of their fathers began exhibiting symptoms commonly known as the “triad” associated with Shaken Baby Syndrome/Abusive Head Trauma (SBS/AHT): subdural hematoma, retinal hemorrhages, and encephalopathy. In each case, a child abuse pediatrician diagnosed the children with SBS/AHT. Both fathers were subsequently charged with aggravated assault and child endangerment based on these findings. The State intended to call the diagnosing physician as an expert witness to testify that, to a reasonable degree of medical certainty, the only plausible explanation for the children’s symptoms was shaking by the caregiver. The defense in both cases moved to exclude this testimony, challenging the scientific reliability of the SBS/AHT theory, specifically the claim that shaking alone, without any impact, can cause the observed injuries.In the Superior Court, following a Frye hearing in one case, the trial judge excluded the SBS/AHT expert testimony, concluding that the scientific basis for the diagnosis was not sufficiently reliable under the Frye standard, particularly given the lack of acceptance in the biomechanical community. The other trial court adopted this determination for the related case. The Appellate Division consolidated the appeals and affirmed both trial courts, holding that SBS/AHT testimony based solely on shaking without impact did not meet the required standard of reliability for expert evidence.The Supreme Court of New Jersey reviewed the cases. It held that the State failed to establish that expert testimony diagnosing SBS/AHT based on shaking without impact is generally accepted in both the medical/pediatric and biomechanical engineering communities, as required under Frye. The Court affirmed the exclusion of the expert testimony and upheld the dismissal of the indictment in one case due to insufficient causation evidence without the barred testimony. View "State v. Nieves" on Justia Law

Late one night in January 2019, three men—Sean Shuler, Javon Abney, and Tyrik Hagood—were shot and killed on a street in Southeast Washington, D.C. Rakeem Willis and Jonathan Winston were charged with three counts of first-degree (premeditated) murder in connection with these deaths. Evidence at trial included eyewitness accounts, forensic findings, and extensive cell phone records, including historical cell site location information (CSLI) used to trace phone movements. The government presented FBI Special Agent Billy Shaw as an expert to interpret the CSLI data, linking Willis’s phones to the vicinity of the crime and subsequent locations.Prior to trial, Winston moved to exclude the CSLI expert’s report and testimony, arguing the government’s notice was insufficient under Superior Court Rule of Criminal Procedure 16 and that the methodology lacked reliability as required by Motorola Inc. v. Murray and Federal Rule of Evidence 702. The motions court admitted the expert testimony over objections, relying on prior experience and cross-examination as safeguards, and declined to hold a Daubert hearing. The trial court later granted Winston’s motion for judgment of acquittal, but Willis was convicted by a jury of all three murder counts and sentenced to 120 years in prison.On appeal, the District of Columbia Court of Appeals found that the motions court failed to properly exercise its gatekeeping role under Rule 702 and Motorola by not sufficiently evaluating whether the expert had reliably applied CSLI methodology to the facts. The appellate court held this error was not harmless, given the centrality of the expert testimony to the government’s case. It therefore reversed Willis’s first-degree murder convictions and remanded for further proceedings. View "Willis v. United States" on Justia Law

A man drove his semi-truck into the shipping yard of a bedding company in Navarro County, Texas, and attempted to attach his truck to a trailer loaded with mattresses and box springs. The trailer was scheduled for authorized pickup by a specific carrier, but the man was neither driving an authorized vehicle nor had he followed the required check-in procedures. An employee grew suspicious, documented the incident, and involved supervisors and police. The man claimed he believed he was lawfully dispatched to pick up the load, but the person he named as his dispatcher denied involvement. The State charged him with cargo theft, alleging that he intentionally conducted an activity—connecting his truck to the trailer—in which he possessed stolen cargo.A jury convicted the man of cargo theft under Texas Penal Code § 31.18(b)(1), and the trial court sentenced him to thirty-seven years’ imprisonment. On appeal, the Tenth Court of Appeals affirmed, finding that the evidence showed he possessed the cargo and that his actions met the statutory definition of conducting an activity involving stolen cargo. The Texas Court of Criminal Appeals initially agreed on some points and remanded for clarification on whether the defendant’s conduct constituted the requisite “activity” under the statute. On remand, the court of appeals again affirmed the conviction, concluding that backing under the trailer and trying to connect brake lines constituted activity in which he possessed stolen cargo.The Texas Court of Criminal Appeals reviewed the case and held that the cargo theft statute is not materially different from the organized retail theft statute and requires proof of conduct distinct from the acts inherent in stealing. Because the only conduct proved was inherent in the theft itself, the evidence was insufficient to support a conviction for cargo theft. The judgment of the court of appeals was reversed, and the case was remanded to consider possible lesser included offenses. View "JOE v. STATE OF TEXAS" on Justia Law

The defendant was indicted for aggravated assault, a second-degree felony, and tried in Harris County district court in January 2023. During the trial, the court required all participants, including witnesses, to wear surgical masks at all times, except when necessary for in-court identifications. The defendant’s counsel objected to the mask mandate on Sixth Amendment grounds, arguing that masking hindered the jury’s ability to assess witness credibility by observing facial expressions. The objection was overruled, and the two key witnesses to the assault testified while masked. The defendant was subsequently convicted.On appeal, the Fourteenth Court of Appeals reversed and remanded the conviction, finding that the mask mandate violated the defendant’s constitutional right to confrontation. The appellate court emphasized that concealing facial features impairs the fact-finder’s ability to evaluate witness demeanor, citing Romero v. State and other precedents. When considering whether this constitutional error was harmless, the court relied on a procedural rule that places the burden on the State to show harmlessness beyond a reasonable doubt. Because the State did not substantively address the issue of harm in its brief, the court presumed harm and reversed the judgment.The Court of Criminal Appeals of Texas reviewed the case. It agreed that the trial court’s mandatory masking policy violated the defendant’s Sixth Amendment right to confrontation, as it did not make any case-specific findings of necessity or individualized determinations for masking. However, the Court held that the appellate court erred by applying a rule of default and presuming harm solely because the State did not brief the issue. The Court clarified that appellate courts have an independent duty to assess harmlessness under Chapman v. California and Rule 44.2(a), regardless of the State’s briefing. The judgment was reversed and remanded to the Fourteenth Court of Appeals to determine whether the error was harmless beyond a reasonable doubt. View "SMITH v. STATE OF TEXAS" on Justia Law

The case concerns a defendant who, after pleading guilty in 2018 to felony larceny with intent to sell and driving with a revoked license, received suspended sentences conditioned on supervised probation. After completing his active sentences in 2021, he began probation but soon failed multiple urine screens, tested positive for cocaine, missed treatment appointments, failed to report to his probation officer, and was arrested for new crimes. His probation officer filed several reports alleging violations of various probation conditions, including failing to report, absconding, and committing new offenses. At his probation revocation hearing, he pleaded guilty to violations based on new convictions but not guilty to technical violations related to reporting and compliance.The Circuit Court of Loudoun County found him guilty of all alleged violations. During sentencing, the court remarked on the defendant’s failure to accept responsibility, among other factors, when determining the sentence. The court ultimately revoked a portion of the suspended sentence, resulting in an active term of incarceration. On appeal, the Court of Appeals of Virginia held that the circuit court improperly considered the defendant’s not-guilty pleas to the technical violations as an aggravating factor at sentencing and reversed for resentencing.The Supreme Court of Virginia reviewed the case and disagreed with the Court of Appeals. The Supreme Court held that the circuit court did not enhance the sentence as punishment for the defendant’s exercise of his right to plead not guilty. Instead, the comments about the failure to accept responsibility were permissible considerations of rehabilitation potential and not explicitly linked to the plea. The Supreme Court reversed the judgment of the Court of Appeals and reinstated the circuit court’s sentence. View "Commonwealth v. Jackson" on Justia Law

Jason Starr, following a contentious divorce from his ex-wife Sara Starr, was required to pay substantial monthly support and other financial obligations. Evidence showed Jason was deeply frustrated by these requirements and expressed anger in personal writings. After Sara moved out, she confided to a friend that she feared Jason would kill her. Prior to the murder, Jason suggested to a friend that his brother Darin could “take care of” marital problems for a fee. Darin, living in Texas, purchased a motorcycle with Jason’s financial assistance and received additional payments from Jason through a third party. Cell-site data and witness testimony placed Darin near Sara’s Alabama residence in the days leading up to her murder. Sara was shot and killed outside her home, and surveillance footage showed a motorcycle leaving the scene shortly after. Darin returned to Texas the same day. Later, while in jail for an unrelated offense, Darin made statements implying Jason owed him a significant favor.A federal grand jury in the United States District Court for the Middle District of Alabama indicted Jason and Darin Starr for using interstate commerce facilities in the commission of a murder-for-hire, in violation of 18 U.S.C. § 1958. At trial, the government presented circumstantial evidence linking both brothers to the crime. The jury convicted both Jason and Darin, and the district court imposed mandatory life sentences.On appeal, the United States Court of Appeals for the Eleventh Circuit reviewed claims that the district court erred by excluding alternate perpetrator evidence, admitting certain hearsay and investigative testimony, and that the evidence was insufficient to support conviction. The Eleventh Circuit held that the district court properly excluded speculative alternate perpetrator evidence, correctly admitted the challenged statements under evidentiary rules, and found the evidence sufficient for conviction. The court affirmed both convictions and sentences. View "USA v. Starr" on Justia Law

The defendant was charged with felony possession of a controlled substance and two related misdemeanors. He and the prosecution entered into a plea agreement under which he would plead guilty to the felony, the misdemeanors would be dismissed, and he would receive a suspended sentence with probation, provided he complied with certain conditions. The agreement included a clause stating it would be “null and void” if the defendant failed to appear for his presentence appointment or sentencing without good cause. After entering his guilty plea, the defendant failed to appear for both the presentence appointment and sentencing, leading to his arrest on a bench warrant.Following these events, the District Court of the Second Judicial District, Nez Perce County, determined that the “null and void” clause released the State and the court from their obligations under the plea agreement, but held that the defendant remained bound by his guilty plea. The court imposed a sentence inconsistent with the plea agreement and did not allow the defendant to withdraw his plea. The Idaho Court of Appeals affirmed the district court’s judgment.On review, the Supreme Court of the State of Idaho held that the district court erred in its interpretation of the “null and void” clause. The Supreme Court concluded that, under general contract principles, the clause rendered the entire plea agreement unenforceable by either party upon breach, not just by the State. The court further held that, under Idaho Criminal Rule 11(f)(4), once the plea agreement was rendered unenforceable and the court declined to be bound by its terms, the defendant was entitled to an opportunity to withdraw his guilty plea. Because the district court failed to provide this opportunity, the Supreme Court vacated the judgment of conviction and remanded the case for further proceedings. View "State v. McGarvey" on Justia Law

Kenneth H. Eastwood was convicted of murder after the body of Cara Hodges was found strangled in a wooded area. Eastwood was the last person seen with the victim and, after being interviewed by police, he confessed to the crime both to his employer and later to law enforcement. During the investigation, Eastwood took a polygraph test and was told by police that he had failed. He subsequently confessed to the murder, describing details of the crime and disposal of evidence. At trial, Eastwood did not testify but presented a false confession expert who opined that his confession was consistent with an internalized false confession, citing factors such as alcohol use, sleep deprivation, and being confronted by police with allegedly objective evidence of guilt.The case was tried in the Circuit Court for Orangeburg County. Eastwood sought to introduce evidence through his expert that police told him he failed the polygraph, arguing it was relevant to his false confession defense. The trial court excluded this evidence, relying on Rule 702 and Rule 403 of the South Carolina Rules of Evidence, finding that polygraph evidence was unreliable and that its admission would confuse the jury and potentially prejudice Eastwood by bolstering the confession’s truthfulness.On appeal, the Supreme Court of South Carolina reviewed whether exclusion of the polygraph evidence was error. The court held that the trial court erred in excluding the evidence under Rule 702, as Eastwood was not offering scientific proof of the polygraph’s reliability but rather the fact that police told him he failed. The Supreme Court found the evidence relevant to the defense and not substantially outweighed by confusion or prejudice under Rule 403. However, the court concluded that the error did not affect the jury’s verdict, as the expert was able to present the core theory of false confessions. The conviction was therefore affirmed. View "The State v. Eastwood" on Justia Law