Justia Criminal Law Opinion Summaries

The Supreme Court affirmed the judgment of the superior court convicting Defendant of assault with a dangerous weapon and resisting arrest, holding that the trial justice did not err by denying Defendant's motion for a new trial. On appeal, Defendant argued that the trial justice overlooked and misconceived material evidence concerning the charges of assault with a dangerous weapon and resisting arrest and therefore erred by denying his motion for a new trial. The Supreme Court affirmed, holding that where the trial justice complied with the directives contained in Rule 33 of the Superior Court Rules of Criminal Procedure and articulated adequate grounds for denying Defendant's motion for a new trial, the justice did not err in denying the motion for a new trial. View "State v. Neugent" on Justia Law

In this case stemming from an incident that allegedly took place while Plaintiff was held in pretrial detention at the Adult Correctional Institutions (ACI) the Supreme Court affirmed the judgment of the superior court in favor of Defendants following entry of an order that denied Plaintiff's motion to file a second amended complaint, holding that Plaintiff was not entitled to relief on his allegations of error. In his complaint, Plaintiff, who was serving consecutive sentences of life imprisonment, alleged that he was attacked by a fellow inmate and that the attack was made possible by a correctional officer. Plaintiff sued ACI, the state, and various John Does, alleging negligence for failing properly to protect him. The trial justice granted Defendants' motion to dismiss based on Rhode Island's civil death statute, R.I. Gen. Laws 13-6-1. Thereafter, the trial justice denied Plaintiff's motion to file a second amended complaint. The Supreme Court affirmed, holding (1) the trial justice properly denied Plaintiff's motion to amend; and (2) Plaintiff's arguments that the civil death statute is unconstitutional on various grounds were barred by the "raise-or-waive" rule and procedural law. View "Gallop v. Adult Correctional Institutions" on Justia Law

The Second Circuit affirmed defendant's conviction for engaging in drug trafficking activity, and conspiring to do so, in violation of the Maritime Drug Law Enforcement Act. The court held that defendant waived his Confrontation Clause and jury trial right challenges to his conviction by pleading guilty. The court also held that the Due Process Clause did not require a nexus between the United States and the MDLEA violations that transpire on a vessel without nationality. The court explained that such prosecutions are not arbitrary, since any nation may exercise jurisdiction over stateless vessels, and they are not unfair, since persons who traffic drugs may be charged with knowledge that such activity is illegal and may be prosecuted somewhere. The court considered defendant's remaining arguments and found them meritless. View "United States v. Van Der End" on Justia Law

The Supreme Court affirmed Defendant's convictions for second-degree rape and simple assault, holding that the circuit court erred when it admitted a narrative report prepared by an emergency room nurse summarizing the victim's oral statements made during a sexual assault examination, but the error was harmless. On appeal, Defendant argued that the circuit court erred in denying his motion for a mistrial and in admitting the sexual assault examination note. The Supreme Court affirmed, holding (1) the circuit court did not err in denying Defendant's motion for a mistrial; and (2) the circuit court erred in admitting the victim's statements describing her assailant and what occurred and what was said after the attack, but the error was harmless because Defendant failed to demonstrate that the error, in all probability, produced some effect upon the final result of the trial. View "State v. Packard" on Justia Law

The Supreme Court affirmed Defendant's conviction of first-degree rape of a child under age thirteen, holding that the circuit court erred in admitting statements from an unavailable witness, but the error was harmless. On appeal, Defendant argued that the trial judge's order admitting, as other acts evidence, statements from an unavailable witness violated his Sixth Amendment right to confront and cross-examine the witnesses against him. The Supreme Court affirmed, holding (1) the statements at issue were testimonial and of a constitutional magnitude; (2) the circuit court's decision to admit the statements violated Defendant's Sixth Amendment right of confrontation; but (3) the affect of the circuit court's error in admitting the statements at trial was harmless beyond a reasonable doubt. View "State v. Richmond" on Justia Law

The Supreme Judicial Court affirmed Defendant's conviction of armed robbery, holding that the motion judge did not err in denying Defendant's motion to suppress evidence of a showup identification but that, for showup identification procedures going forward, the officers conducting the showup will be required to provide instructions similar to those used in identifications through photographic arrays. In his appeal, Defendant argued (1) the showup identification evidence should have been suppressed because the procedure was so unnecessarily suggestive and conducive to mistaken identification that it denied him due process of law, and (2) the trial judge erred on several evidentiary rulings on eyewitness identification. The Supreme Judicial Court affirmed, holding (1) there was no abuse of discretion in the trial judge's determination that the identification procedure in this case was not unnecessarily suggestive; (2) following issuance of the prescript in this case, police are required to provide witnesses with an instruction prior to showup identification similar to those used in identifications through photographic arrays; and (3) there was no reversible error in the trial judge's evidentiary rulings on eyewitness identification. View "Commonwealth v. German" on Justia Law

Robert Tran was convicted by jury of reckless driving. He was sentenced to three years' probation with 30 days in custody. Tran appealed, contending the trial court erred in denying his pretrial motion to suppress evidence obtained from the warrantless search of his backpack and seizure of his dashboard camera. Tran claimed exigent circumstances did not exist; thus, law enforcement was not excused from first obtaining a warrant. After review, the Court of Appeal determined the seizure of Tran's dashboard camera was constitutional, and that the trial court did not err in denying Tran's motion to suppress. View "California v. Tran" on Justia Law

The Supreme Court affirmed Defendant's conviction of five separate misdemeanor thefts aggregated into a single Class D felony, holding that the separate misdemeanor thefts were properly aggregated into a single felony charge and that the evidence sufficiently established that the separate thefts arose from a common scheme, purpose, intent, or enterprise. The separate misdemeanor thefts were aggregated into a single felony count pursuant to Tenn. Code Ann. 39-14-105(b)(1), which provides that, in a prosecution for theft of property, the State may charge multiple criminal acts committed against one or more victims as a single count of the criminal acts arose from a common scheme, purpose, intent or enterprise. On appeal, Defendant argued that the separate thefts may be aggregated only when the thefts are from the same owner, from the same location, and pursuant to a continuing criminal impulse or a single sustained larcenous scheme. The Supreme Court disagreed, holding (1) the statutory aggregation provision does not incorporate the limitations expressed in Byrd, and the aggregation of the five alleged thefts into one count in this case was not improper; and (2) there was sufficient evidence for the jury to aggregate the five alleged thefts into one count. View "State v. Jones" on Justia Law

The Fifth Circuit denied TDCJ's motion to vacate the district court's order granting Texas death row inmate Patrick Henry Murphy's motion seeking to stay his execution. The court held that the district court did not abuse its discretion in granting the stay and agreed with the district court's implicit finding that Murphy had a strong likelihood of success on the merits of his claim that the TDCJ policy violates his rights by allowing inmates who share the same faith as TDCJ-employed clergy greater access to a spiritual advisor in the death house. The court held that Murphy's claim was timely, and rejected TDCJ's exhaustion argument. View "Murphy v. Collier" on Justia Law

The Supreme Court affirmed the decision of the court of appeals affirming Defendant's conviction of first-degree manslaughter, holding that the plain language of the first-degree manslaughter statute, Minn. Stat. 609.20(2), does not require the State to prove that death or great bodily harm was a reasonably foreseeable result when the underlying crime is fifth-degree assault. On appeal, Defendant argued that the district court erred by failing to instruct the jury that a conviction for first-degree manslaughter required proof that he committed fifth-degree assault with such violence or force that great bodily harm or death was reasonably foreseeable. The court of appeals affirmed, concluding that the district court did not err in declining to so instruct the jury. The Supreme Court affirmed, holding that section 609.20(2) does not require the State to prove that death or great bodily harm was a reasonably foreseeable result of the defendant's conduct when the underlying crime is fifth-degree assault. View "State v. Stay" on Justia Law