Justia Criminal Law Opinion Summaries

Staci Broome was convicted of aggravated assault after an altercation with Julie Mathis, the daughter of Broome's boyfriend, Michael Mathis. The incident occurred when Julie was at her father's house doing schoolwork, and Broome, upon learning of Julie's presence, confronted her. The confrontation escalated into a physical fight, during which Broome hit Julie with a metal object, causing significant injuries.The case was initially tried in the Simpson County Circuit Court, where the jury found Broome guilty of aggravated assault. Broome was sentenced to twenty years, with fifteen years to serve and five years of supervised probation. Broome appealed her conviction, arguing that the trial court erred by allowing hearsay testimony and lay opinion testimony on the ultimate issue.The Supreme Court of Mississippi reviewed the case. Broome contended that the trial court improperly admitted hearsay testimony from Investigator Brian Green, who testified about statements made by Julie Mathis during his investigation. The court found that Green's testimony about the metal object was not hearsay because it was offered to explain the steps he took during his investigation. Although the court acknowledged that Green's repetition of Julie's identification of Broome was hearsay, it deemed the error harmless given the overwhelming evidence against Broome.Broome also argued that the trial court erred by allowing Green to express his opinion on the ultimate issue of the case. The Supreme Court found that any error in admitting this testimony was harmless due to the substantial evidence presented by the State, including testimonies from Julie, Amber (Broome's daughter), and Michael, as well as physical evidence.The Supreme Court of Mississippi affirmed Broome's conviction and sentence. View "Broome v. State of Mississippi" on Justia Law

Kenneth Vaughn, a self-described Moorish National, was convicted by a jury of six counts of offering a false instrument for filing or record, two counts of simulation of summons, complaint, judgment, order, or other legal process, and two counts of intimidating a public officer. Vaughn sent documents to his landlords and the Clark County Recorder's office, claiming ownership of properties he did not own and threatening public officers when his documents were not recorded. He was sentenced as a habitual criminal to an aggregate prison term of 5-20 years and ordered to pay $19,600 in restitution.The Eighth Judicial District Court in Clark County adjudicated Vaughn as a habitual criminal and denied his motion to dismiss the indictment on speedy trial grounds. Vaughn represented himself at trial with standby counsel and was convicted on all counts. He appealed his conviction and sentence, arguing several grounds including the denial of his motion to dismiss, insufficient evidence, prejudicial witness testimony, misleading jury instructions, improper habitual criminal adjudication, and an unsupported restitution award.The Supreme Court of Nevada reviewed the case and held that the State failed to prove the elements of the charges under NRS 239.330(1) because the documents Vaughn attempted to record were not of a type that could be recorded under state or federal law. Consequently, the court reversed Vaughn's conviction on the six counts of offering a false instrument for filing or record. The court also reversed the restitution award, finding that the district court relied on impalpable or highly suspect evidence. However, the court affirmed Vaughn's conviction on the remaining counts and upheld the habitual criminal adjudication and the sentence imposed for those counts. View "VAUGHN VS. STATE" on Justia Law

The defendant was convicted in district court for second-degree murder under La. R.S. 14:30.1(A)(3) for providing drugs that led to the poly drug toxicity death of the victim. The incident involved the victim, Brittany Lapeyrouse, who died on September 19, 2018, after consuming various drugs. The defendant and two co-defendants were initially charged with multiple felonies, including negligent homicide. A superseding indictment charged the defendant alone with second-degree murder, possession of methamphetamine with intent to distribute, possession of alprazolam, and illegal carrying of weapons while in possession of controlled dangerous substances. The defendant pleaded not guilty, but a jury found him guilty on all counts.The Court of Appeal, Third Circuit, reversed the second-degree murder conviction, citing insufficient evidence. The appellate court noted that while there was evidence the defendant sold methamphetamine to the victim, there was no direct evidence that the victim ingested the methamphetamine sold by the defendant. The court also highlighted that the victim had access to drugs from other sources and was not in the defendant's company for extended periods on the day of her death. The appellate court concluded that the prosecution failed to exclude every reasonable hypothesis of innocence, as required by La. R.S. 15:438.The Supreme Court of Louisiana reviewed the case and affirmed the appellate court's decision. The court held that the evidence was insufficient to prove that the methamphetamine sold by the defendant was the direct cause of the victim's death. The court emphasized that the statute requires proof that the controlled substance distributed by the defendant was the direct cause of death, which was not established in this case. The court also noted that the State's expert could not definitively state that the methamphetamine alone caused the death, as the victim had multiple drugs in her system. View "STATE OF LOUISIANA VS. BARTIE" on Justia Law

The defendant, Kendall Cecil Morgan, was charged with home invasion and domestic battery for allegedly entering Vanessa Williams' apartment without authority and striking her in the face. The State filed a petition to deny Morgan pretrial release, citing the charges and arguing that his release posed a threat to the community. At the detention hearing, the State presented evidence of the charges and Morgan's criminal history, including a previous conviction for armed robbery and pending cases for DUI and battery. The defense argued that Morgan had been diagnosed with bipolar disorder and suggested conditions like electronic monitoring and mental health treatment.The McLean County Circuit Court found that the State had established by clear and convincing evidence that Morgan committed the offenses, posed a threat to the community, and that no conditions could mitigate his dangerousness. The court granted the State's petition to deny pretrial release. Morgan appealed, arguing that the State had not met its burden and that the appellate court should review the circuit court's decision de novo.The Illinois Appellate Court reviewed the circuit court's decision for an abuse of discretion and upheld the denial of pretrial release. The appellate court reasoned that the circuit court's ability to observe the defendant warranted deference, even when the evidence was presented by proffer.The Illinois Supreme Court reviewed the case to determine the appropriate standard of review for pretrial detention decisions under section 110-6.1 of the Code of Criminal Procedure. The court held that when live testimony is presented, the circuit court's decision should be reviewed under the manifest weight of the evidence standard. However, when the parties proceed solely by proffer, the reviewing court should conduct a de novo review. Applying de novo review, the Supreme Court affirmed the circuit court's judgment denying Morgan pretrial release. View "People v. Morgan" on Justia Law

The defendant was convicted of unlawful possession of a controlled substance after a stipulated bench trial. The conviction stemmed from evidence found in a locked kitchen cabinet during a warrantless search by police officers who were investigating a gas leak in the defendant's home. The defendant filed a motion to suppress the evidence, arguing that the search was unreasonable and violated the Fourth Amendment. The trial court denied the motion, and the defendant was subsequently convicted.The Second District Appellate Court affirmed the conviction, holding that the police officers' actions were permissible under the community caretaking or emergency aid exceptions to the warrant requirement. The appellate court found that the use of a flashlight to look into the cabinet did not constitute a search under the Fourth Amendment. One justice dissented, arguing that the use of the flashlight to peer into a locked cabinet was a search in violation of the Fourth Amendment.The Supreme Court of Illinois reviewed the case and reversed the lower courts' judgments. The court held that the contraband found in the locked cabinet was not in plain view and that the police officers' actions constituted an unreasonable search. The court concluded that the use of a flashlight to look into the cabinet, which was secured with a chain and padlock, amounted to a search that was not justified by the emergency aid or community caretaking exceptions. As a result, the trial court erred in denying the defendant's motion to suppress the evidence. The Supreme Court reversed the defendant's conviction and vacated his sentence. View "People v. Hagestedt" on Justia Law

In 2021, Aaron Von Ehlinger, a first-year member of the Idaho State House of Representatives, was accused of rape by J.V., a legislative intern. They had dinner together and later went to Von Ehlinger’s apartment, where J.V. alleged that he sexually assaulted her. Von Ehlinger claimed the encounter was consensual. J.V. reported the incident, and a forensic nurse, Ann Wardle, conducted a sexual assault examination, documenting J.V.'s account and collecting evidence. Von Ehlinger was charged with rape and sexual penetration by use of a foreign object.The case proceeded to trial in April 2022 in the District Court of the Fourth Judicial District of Idaho. During the trial, Wardle testified about J.V.'s statements, which were admitted despite objections from Von Ehlinger’s defense on hearsay grounds. J.V. testified briefly but left the courtroom before cross-examination, leading the court to strike her testimony. The jury found Von Ehlinger guilty of rape but acquitted him of the second charge. The district court denied Von Ehlinger’s motion for acquittal or a new trial and sentenced him to 20 years in prison, with 8 years fixed.The Idaho Supreme Court reviewed the case. Von Ehlinger argued that his Sixth Amendment rights were violated by the admission of Wardle’s testimony and that the district court erred in allowing a leading question. The court found that Von Ehlinger failed to demonstrate that the admission of Wardle’s testimony was fundamental error, as his counsel’s failure to object could have been a tactical decision. The court also determined that any error in allowing the leading question was harmless, as Wardle did not answer the question directly. The court affirmed the judgment of conviction, concluding that there was sufficient evidence to support the jury’s verdict. View "State v. Von Ehlinger" on Justia Law

The case involves William Donnette Sanders, who was convicted of multiple possessory offenses related to drugs, a gun, and other paraphernalia found in his car. The police discovered these items during a search of Sanders' person and vehicle after executing a search warrant at an apartment. Sanders was present at the apartment and was detained and questioned by the police, during which he made statements about his car. Sanders challenged the admissibility of these statements, arguing they were obtained in violation of his Miranda rights. He also filed a post-conviction motion alleging ineffective assistance of counsel for failing to file a motion to suppress evidence obtained from the search of his person.The Superior Court of the District of Columbia denied Sanders' motion to suppress his statements, concluding there were no Miranda violations. The court also denied his Section 23-110 motion, finding that his trial counsel was not deficient and that the search was lawful. Sanders was convicted by a jury on all counts and sentenced to seventy-two months of imprisonment with five years of supervised release.The District of Columbia Court of Appeals reviewed the case and determined that Sanders was in custody for Miranda purposes when he made statements to the police without receiving Miranda warnings. However, the court found that the error in admitting these statements was harmless because there was no reasonable possibility that the statements contributed to Sanders' conviction, given the strong evidence connecting him to the contraband.The court also affirmed the denial of Sanders' Section 23-110 motion, concluding that a motion to suppress the key fob and $1,000 would have been unsuccessful and that Sanders was not prejudiced by his trial counsel's performance. The court found sufficient evidence to support Sanders' convictions for constructive possession, noting his ownership of the car, proximity to the contraband, and the presence of his personal belongings interspersed with the contraband.The District of Columbia Court of Appeals affirmed Sanders' convictions and the trial court's denial of his Section 23-110 motion. View "Sanders v. United States" on Justia Law

The defendants, Nicholas Sicellon and Jerion Moore, were indicted for first-degree murder and unlicensed possession of a firearm. Their first trial in December 2021 ended in a mistrial due to a deadlocked jury. In their second trial in July 2022, the jury again could not reach a unanimous verdict, leading the trial judge to declare a mistrial after the jury reported twice that they were deadlocked. The defendants filed motions to dismiss the charges on double jeopardy grounds, arguing that the mistrial was declared without manifest necessity and that the evidence was insufficient to identify them as the perpetrators. These motions were denied.The defendants then petitioned a single justice of the Supreme Judicial Court for extraordinary relief under G. L. c. 211, § 3, which was also denied. They appealed this decision, arguing that the trial judge improperly declared a mistrial without manifest necessity and that the evidence was insufficient to support their identification as the shooters.The Supreme Judicial Court reviewed the case and concluded that the trial judge did not abuse her discretion in declaring a mistrial. The judge had given careful consideration to the alternatives and determined that further deliberations would be coercive given the jury's unequivocal statements of deadlock. The court also found that the evidence presented at the second trial was sufficient for a rational trier of fact to identify the defendants as the perpetrators beyond a reasonable doubt.The Supreme Judicial Court affirmed the single justice's denial of the defendants' petitions, holding that there was no clear error of law or abuse of discretion in the denial of relief. The judgments of the single justice were affirmed, allowing the Commonwealth to retry the defendants. View "Sicellon v. Commonwealth" on Justia Law

The petitioner, Dana Stubblefield, was convicted in 2020 of forcible rape and related offenses and sentenced to 15 years to life in prison. On direct appeal, the conviction was found legally invalid due to a violation of the California Racial Justice Act (RJA). The appellate court reversed the judgment, vacated the conviction and sentence, and remanded the case for new proceedings. Before the remittitur issued, Stubblefield filed a motion for release on his own recognizance or on bail, which the trial court denied, citing lack of jurisdiction.The trial court, upon receiving the jury's verdict in July 2020, remanded Stubblefield into custody, and he was sentenced in October 2020. Stubblefield appealed in November 2020, arguing that the prosecution violated the RJA. The appellate court agreed, reversed the conviction, and remanded the case. Stubblefield then sought release pending the final outcome of the appeal, but the trial court denied the motion, stating it lacked jurisdiction without the remittitur. Stubblefield petitioned the appellate court for a writ of mandate to compel the trial court to rule on his motion.The California Court of Appeal, Sixth Appellate District, reviewed the case and concluded that the trial court had jurisdiction to rule on Stubblefield's motion for release pending appeal, despite the remittitur not yet issuing. The court held that the trial court's jurisdiction to hear a motion for release is supported by the Penal Code, which allows for bail after conviction and pending appeal. The appellate court issued a peremptory writ of mandate directing the trial court to vacate its decision and rule on the merits of Stubblefield's motion for release. View "Stubblefield v. Super. Ct." on Justia Law

Joseph Eugene Garcia was charged with multiple counts of sexual intercourse without consent and sexual abuse of children, involving the repeated rape of an underage boy, C.C., over five years. On the day of the trial, Garcia entered an Alford plea to a single amended charge of felony sexual assault, and the State agreed to drop the original charges and recommend a sentence of forty years, with twenty years suspended. The plea agreement did not address the sex offender tier level designation.The District Court ordered a presentence investigation (PSI) and a psychosexual evaluation (PSE), which were completed by Dr. Robert Page. Dr. Page recommended a tier level 1 sexual offender designation, indicating a low risk of re-offense. However, he noted limitations in the risk assessment tools and suggested that additional victims were likely. At the sentencing hearing, the State presented testimony from several witnesses, including Sergeant Kaylin Cunningham, who provided evidence of Garcia's grooming tactics and possession of items used to manipulate and control his victims. Victim impact statements from C.C. and his mother expressed concerns about Garcia's future risk to children.The District Court sentenced Garcia to forty years in prison, with twenty years suspended, and designated him as a tier level 2 sexual offender, citing the extensive use of grooming tactics and the likelihood of multiple victims. Garcia appealed, arguing that the District Court improperly considered evidence beyond the psychosexual evaluation report in determining his tier level designation.The Supreme Court of the State of Montana reviewed the case and affirmed the District Court's decision. The Court held that the District Court correctly interpreted the statute, which allows the court to consider a broad range of information, including victim impact statements and other relevant evidence, when designating a sexual offender tier level. The Court found no abuse of discretion in the District Court's designation of Garcia as a tier level 2 sexual offender. View "State v. Garcia" on Justia Law