Justia Criminal Law Opinion Summaries

The case concerns an individual who, after being arrested and brought to jail by police officers, was found to have a small canister of pepper spray in his pocket. The defendant was impaired at the time of his arrest and was passively noncompliant, which led officers to skip some standard search procedures and place him directly in a cell. Several hours later, the defendant discovered the pepper spray in his pocket and alerted officers to its presence but did not immediately relinquish the item. Instead, he attempted to use the pepper spray as leverage for demands such as a phone call and a cell transfer and only surrendered the canister after officers deployed pepper spray into his cell.The State charged the defendant with felony possession of material capable of causing bodily injury by an incarcerated person under Indiana Code section 35-44.1-3-7. At trial in Elkhart Superior Court, a jury found him guilty, and the court imposed a four-year sentence. On appeal, the defendant argued that the evidence was insufficient to prove that he knowingly possessed the pepper spray in jail, since he had not voluntarily brought it into the facility or received a reasonable opportunity to relinquish it. The Indiana Court of Appeals agreed with the defendant, reversed the conviction, and found that he had not received a reasonable opportunity to purge himself of the item.The Indiana Supreme Court granted transfer, vacating the Court of Appeals’ opinion. The Indiana Supreme Court held that under Indiana Code section 35-44.1-3-7, an incarcerated person is prohibited from knowingly retaining possession of prohibited material after receiving a reasonable opportunity to relinquish it, regardless of how the item entered the facility. The Court found sufficient evidence that the defendant failed to surrender the pepper spray at the earliest reasonable opportunity and affirmed his conviction. View "Gary v. State" on Justia Law

In 2016, the defendant was convicted of multiple felonies and misdemeanors for violent offenses against his wife and a neighbor. He received a sentence that included a lengthy state prison term for the felonies and a consecutive county jail term for the misdemeanors. After a direct appeal, the California Court of Appeal, Fourth Appellate District, Division One, reversed one felony conviction but affirmed the rest and remanded the case for further proceedings on the reversed count. On remand in 2019, the trial court resentenced the defendant, but a clerical error led to the inclusion of misdemeanor jail time in the calculation of the total state prison term.Following this, a records analyst from the Department of Corrections notified the trial court in 2024 about the error in the abstract of judgment. The Superior Court of Riverside County held a hearing to address the issue. During this hearing, defense counsel requested a full resentencing, a Romero motion to dismiss a strike, and reconsideration of the upper term on one count. The court denied these requests, determining that only a clerical correction was required. However, the court also modified the misdemeanor sentences, reducing their terms and making them concurrent, changes for which it lacked jurisdiction.The California Court of Appeal, Fourth Appellate District, Division One, reviewed the case and held that the error in the 2019 sentence was clerical, not judicial, and thus did not entitle the defendant to a full resentencing. The appellate court affirmed the denial of resentencing and the Romero motion. However, it found that the trial court exceeded its authority by modifying the misdemeanor sentences and vacated that portion of the order. The case was remanded with instructions to correct the abstract of judgment to reflect the original 2019 sentence. View "People v. Sanchez" on Justia Law

The case concerns a man convicted of the 1989 murders of his girlfriend and her daughter in Arizona. He was found guilty by a jury and subsequently sentenced to death by a judge. The sentencing judge identified multiple aggravating factors, including the especially cruel nature of the crimes, multiple victims, and prior violent felonies. The judge also found statutory and non-statutory mitigating factors, such as the defendant’s impaired capacity, troubled childhood, and psychological issues. After his conviction and sentencing were affirmed on direct appeal by the Arizona Supreme Court, the defendant sought postconviction relief in state court through three separate petitions. His first petition did not raise an ineffective assistance of counsel (IAC) claim and was handled by counsel later conceded to be ineffective. A second petition, raising the IAC claim, was denied as untimely. A third petition argued he was intellectually disabled and therefore ineligible for execution, but that claim was rejected after an evidentiary hearing.In federal court, the petitioner’s IAC claim was initially deemed procedurally defaulted by the United States District Court for the District of Arizona. Subsequent Supreme Court and Ninth Circuit decisions, including Martinez v. Ryan, allowed for the possibility that ineffective postconviction counsel could excuse such defaults. The Ninth Circuit originally remanded for an evidentiary hearing, but the United States Supreme Court reversed, holding that federal courts may not expand the state court record based on ineffective state postconviction counsel.On remand, the United States Court of Appeals for the Ninth Circuit considered only evidence properly submitted in state court under procedural rules. The Ninth Circuit found the petitioner demonstrated “cause” to excuse the procedural default but failed to show “prejudice,” as his underlying IAC claim was not “substantial.” Although counsel’s performance was deficient, the new mitigating evidence was unlikely to have changed the sentencing outcome, given the weight of aggravating factors and Arizona precedent. The Ninth Circuit affirmed the district court’s denial of habeas relief. View "RAMIREZ V. THORNELL" on Justia Law

The case involved a dispute between two neighbors in an apartment complex. The defendant parked in another tenant’s assigned parking spot, leading to an argument in which the other tenant, KC, claimed that the defendant brandished a gun and threatened him. The defendant denied displaying a weapon, although he admitted owning a gun matching KC’s description, which police later found secured in his apartment. The defendant was charged with unlawful use of a weapon involving the threatened use of a firearm. At trial, a police officer testified about his perceptions of both parties’ demeanor and, upon questioning by the prosecutor, stated that he believed the defendant was not truthful. The defense did not object to this testimony.After the jury convicted the defendant, the Multnomah County Circuit Court sentenced him to probation. On appeal, the Oregon Court of Appeals affirmed the conviction, concluding that the admission of the officer’s vouching testimony was not plain error warranting reversal. The appellate court reasoned that it was plausible the defendant had a strategic reason for not objecting, such as supporting a defense theory that police were biased or conducted an inadequate investigation. The Court of Appeals also noted that, even if the admission was plain error, it would not exercise its discretion to reverse the conviction because the error was not grave and could have been easily remedied if an objection had been made.The Supreme Court of the State of Oregon reviewed whether the possibility of a strategic decision not to object to vouching testimony affects plain-error review. The court held that the admission of such testimony, if categorically prohibited, is plain error regardless of possible trial strategy. However, whether to reverse a conviction for that error is a discretionary decision, and the Court of Appeals did not abuse its discretion in declining to reverse. The decisions of the Court of Appeals and the circuit court were affirmed. View "State v. Hutchings" on Justia Law

A defendant was charged with multiple crimes and tried by jury in Washington County Circuit Court. After the jury was selected but before opening statements, the trial judge provided the jury with written instructions and read them aloud. These initial instructions covered issues such as the presumption of innocence, the state’s burden of proof, a defendant’s right not to testify, and other basic legal principles. The trial court informed the jury that these were “precautionary” instructions and that further instructions would be given after the close of evidence. When the evidence concluded, the court distributed a new set of written instructions but declined to reread several key instructions it had previously given orally at the outset of trial. The defendant objected, specifically requesting that the court reread instructions on the presumption of innocence, burden of proof, and right not to testify, but the court declined, leaving those instructions only in written form.The jury convicted the defendant on all counts. The defendant appealed to the Oregon Court of Appeals, arguing that the trial court’s failure to reread the key instructions at the end of the trial violated Oregon Rule of Civil Procedure (ORCP) 59 B, which requires the court to “state to the jury all matters of law necessary for its information in giving its verdict.” The state countered that the trial court had discretion regarding the timing of jury instructions under ORCP 58 and that any error was harmless because the instructions were provided in writing. The Court of Appeals ruled in favor of the defendant, holding that ORCP 59 B required the trial court to orally restate the necessary legal instructions at the close of trial and that the omission was not harmless.The Supreme Court of the State of Oregon affirmed the decision of the Court of Appeals, reversed the circuit court judgment, and remanded for further proceedings. The court held that ORCP 59 B requires the trial court to orally instruct the jury at the end of trial on all matters of law necessary for its verdict, and that this requirement is not satisfied by earlier oral instructions or written instructions alone. The error was not harmless. View "State v. Shine" on Justia Law

After a long-term romantic relationship began to deteriorate between Elijah Singleton and Ja’Keya Hampton, Singleton stole Hampton’s cellphone and refused to return it. The day before Hampton’s death, the two communicated via Facebook Messenger, arranging to meet so Singleton could return the phone. Hours later, Hampton was found dead in her car from a gunshot wound. Surveillance footage captured the shooting, with audio indicating Hampton called out to Singleton moments before being shot. After the incident, Singleton attempted to elude law enforcement and destroy evidence, but was arrested following a standoff. He was charged with capital murder and a firearm enhancement.During jury selection in the Crittenden County Circuit Court, a prospective juror who worked at the county jail expressed concerns about a conflict of interest in open court, prompting Singleton to move for a mistrial, which was denied. The State exercised peremptory strikes against four Black prospective jurors. Singleton raised a Batson challenge, arguing the strikes were racially motivated. The State provided race-neutral reasons, such as relationships with the victim’s family, perceived reluctance to serve, and inattentiveness. The circuit court credited the State’s reasons, found them race-neutral, and denied the Batson challenge. Singleton was convicted of first-degree murder and employing a firearm, and sentenced as a habitual offender.On appeal, the Supreme Court of Arkansas reviewed Singleton’s claims that the circuit court erred in denying his mistrial motion and his Batson challenge. The court held there was no abuse of discretion in denying the mistrial because the prospective juror’s statement did not prejudice the jury. It further held that the circuit court’s findings regarding the Batson challenge were not clearly against the preponderance of the evidence. The Supreme Court of Arkansas affirmed the convictions. View "SINGLETON v. STATE OF ARKANSAS" on Justia Law

After severely assaulting his mother in December 2017 and causing serious injuries, Akeel Bin-Bellah was charged by the State of Washington with first degree assault. In plea negotiations, the State agreed to reduce the original charge and, in a global agreement that also resolved an unrelated robbery case, Bin-Bellah pleaded guilty to one count of second degree assault and three counts of fourth degree assault, all relating to the same incident. As part of his plea, Bin-Bellah expressly stipulated that each count of assault represented a separate and distinct act, and acknowledged that his plea was knowing and voluntary. The plea arrangement substantially reduced his potential sentence compared to the original charges.Following sentencing in King County Superior Court, Bin-Bellah filed a motion for relief, contending that his multiple assault convictions violated double jeopardy because they all arose from a single criminal act. This motion was transferred to the Washington Court of Appeals, Division One, which granted his personal restraint petition. The Court of Appeals concluded that the record showed only one criminal act, found a double jeopardy violation, vacated the three fourth degree assault convictions, and remanded for resentencing on the remaining count.The Supreme Court of the State of Washington reviewed the case after granting discretionary review. The Supreme Court reversed the Court of Appeals. It held that under Washington’s flexible plea bargaining framework, a defendant may knowingly and voluntarily plead guilty to multiple lesser charges—even if they are legally or factually duplicative—so long as there is a factual basis for the original charge and the plea includes explicit factual stipulations to support the convictions. Because Bin-Bellah’s plea included such stipulations and was knowing and voluntary, his double jeopardy claim was foreclosed. The Supreme Court reinstated all his convictions and dismissed his personal restraint petition. View "In re Pers. Restraint of Bin-Bellah" on Justia Law

The case concerns a noncitizen, a native and citizen of Ecuador, who entered the United States without authorization around 1999. In 2009, he was convicted of reckless assault of a child and sentenced to three years in prison. During removal proceedings in 2010, the immigration judge advised him that his conviction made him ineligible for voluntary departure and offered removal instead. The noncitizen, after confirming his understanding of his rights and waiving his right to counsel and appeal, was removed to Ecuador in 2011. He later reentered the United States without permission and was arrested in 2021. In 2022, he was charged with aggravated illegal reentry.In the United States District Court for the Southern District of New York, the defendant moved to dismiss the criminal information, arguing that recent Supreme Court precedent established he had, in fact, been eligible for voluntary departure at his 2010 hearing, and that the immigration judge’s erroneous advice rendered the proceedings fundamentally unfair. The District Court, relying on prior Second Circuit precedent from United States v. Sosa, excused the defendant’s failure to exhaust administrative remedies and granted the motion to dismiss, finding his waiver of appeal was not knowing and intelligent due to the immigration judge’s mistake.The United States Court of Appeals for the Second Circuit reviewed the case. It held that the Supreme Court’s decision in United States v. Palomar-Santiago made clear that all three requirements of 8 U.S.C. § 1326(d)—exhaustion of administrative remedies, deprivation of opportunity for judicial review, and fundamental unfairness—are mandatory and cannot be excused by courts. Because the defendant failed to exhaust administrative remedies and was not deprived of the opportunity for judicial review, he was barred from collaterally attacking his removal order. The Second Circuit reversed the District Court’s dismissal and remanded the case for further proceedings. View "United States of America v. Mejia" on Justia Law

The case involves Richard Romanyshyn, who was subject to a disorderly conduct restraining order (DCRO) issued in Stark County, North Dakota, which included two minor children as protected parties. Romanyshyn was personally served with the DCRO and did not appeal it. Later, he allegedly violated the order by sending text messages to one or more protected parties. Subsequently, he was charged with violating the DCRO, a class A misdemeanor. Separately, a DCRO was issued against him in Hettinger County involving the same parties, but the North Dakota Supreme Court later reversed that order and remanded for an evidentiary hearing in Davis v. Romanyshyn, 2025 ND 18.After the Supreme Court’s reversal of the Hettinger County DCRO, Romanyshyn moved to dismiss the Stark County criminal charge, arguing that the DCRO in his case was invalid under the Davis precedent. The State responded that the Supreme Court’s decision in the Hettinger County matter did not affect the Stark County DCRO. The District Court of Stark County denied Romanyshyn’s motion to dismiss, finding that his challenge was a legal, not factual, one, and that no evidentiary hearing or factual findings were necessary.On appeal, the Supreme Court of North Dakota reviewed the district court’s denial of the motion to dismiss. The Court held that because Romanyshyn’s argument was purely legal and not dependent on disputed facts, the district court was not required to make factual findings. Further, the Supreme Court determined that the district court did not improperly take judicial notice of adjudicative facts. The Court declined to address the merits of the collateral attack argument because Romanyshyn did not brief the issue. The Supreme Court of North Dakota affirmed the amended criminal judgment. View "State v. Romanyshyn" on Justia Law

The defendant was charged with robbery and reckless endangerment in December 2024 while on parole for a prior conviction. He was arrested on December 18, 2024, did not post bond, and his parole was revoked during his pretrial custody. In June 2025, the robbery charge was amended to aggravated assault, and the defendant pled guilty to both aggravated assault and reckless endangerment. The district court sentenced him to five years for aggravated assault and two years for reckless endangerment, to run consecutively and consecutive to another sentence not at issue. The court did not give the defendant credit for time served in custody between his arrest and sentencing.The District Court of Burleigh County, South Central Judicial District, presided over sentencing. The defendant argued at sentencing that he should receive credit for time served from his arrest, claiming his custody was due to the new charges. The State contended the custody resulted from his parole revocation on a previous conviction. The defendant’s attorney acknowledged the parole was revoked five days after arrest but presented no evidence regarding the timing or application of credit. The district court found the time in custody was due to the parole violation, not the new charges, and denied credit for time served. The defendant appealed the sentence, claiming entitlement to credit and arguing the State bore the burden to prove facts supporting the denial.The Supreme Court of North Dakota reviewed the case. It held that under North Dakota law, the burden is on the defendant to show entitlement to credit for time served, and a defendant is not entitled to credit for time served on an unrelated prior conviction. The court found no abuse of discretion or illegality in the sentence, as it was within statutory limits and based on proper factors. The Supreme Court of North Dakota affirmed the criminal judgment. View "State v. Barse" on Justia Law