Justia Criminal Law Opinion Summaries

Bryant D. Aron was indicted by a grand jury for possession of a firearm and ammunition as a felon, a violation of 18 U.S.C. § 922(g)(1). Initially, Aron agreed to plead guilty under a binding plea agreement, which recommended a sentence of 96 months' imprisonment. However, the district court refused to accept this sentencing recommendation. As the plea agreement was binding, Aron was given the option to withdraw his guilty plea, which he did. Instead of negotiating a different plea agreement, Aron chose to proceed to trial. He was convicted by a jury and sentenced to the statutory maximum of 120 months' imprisonment.The district court's refusal to accept the sentencing recommendation in the plea agreement led to Aron's decision to withdraw his guilty plea and proceed to trial. After his conviction and sentencing, Aron appealed, raising several challenges to the indictment and the plea and sentencing process. He argued that the indictment failed to include a known and necessary element, that he had good cause for not raising this objection in the district court, and that the deficiency in the indictment was either structural error or met the plain error standard.The United States Court of Appeals for the Seventh Circuit rejected Aron's arguments. The court found that the indictment was not defective and that Aron had failed to raise his objection in a timely manner. The court also found that Aron had not demonstrated good cause for his failure to raise the objection pretrial. Therefore, the court did not conduct a plain error review of his claim.Aron also challenged the district court's rejection of his binding plea agreement. He argued that the court had improperly inserted itself into the plea negotiation process, failed to provide a sound reason for rejecting the plea agreement, and did not provide enough notice of its rejection of the plea agreement. The Court of Appeals rejected these arguments as well, affirming the decision of the district court. View "USA v. Aron" on Justia Law

The case involves Terril Edwards, who was convicted in 2008 on three counts: possession with intent to distribute more than 50 grams of crack cocaine, carrying a firearm during and in relation to a drug trafficking crime, and possession of a firearm by a felon. Based on Edwards’s criminal history, the District Court determined that the statutory minimum for the Drug Trafficking Charge was life imprisonment. In 2011, Edwards filed a motion to vacate, set aside, or correct his sentence, which the District Court denied. In 2019, following the passage of the First Step Act of 2018, Edwards filed a motion for resentencing. The District Court granted the motion and resentenced Edwards to a total of 240 months.Edwards's conviction and sentence were affirmed by the United States Court of Appeals for the Third Circuit. In 2020, Edwards filed a second motion to vacate, set aside, or correct his sentence in light of the Supreme Court’s decision in Rehaif v. United States. The District Court transferred the petition to the Third Circuit to determine whether it could consider the successive petition.The United States Court of Appeals for the Third Circuit held that Edwards's second motion was a second or successive motion because a First Step Act resentencing is unrelated to the validity of the judgment it amends and thus does not result in a new, intervening judgment under Magwood. The court also held that Edwards had not satisfied the requirements of § 2255(h) because Rehaif did not announce a “new rule of constitutional law” made retroactive to cases on collateral review by the Supreme Court. Finally, the court held that Edwards could not challenge his sentence under 28 U.S.C. § 2241, as the Supreme Court had foreclosed this possibility in Jones v. Hendrix. As a result, the court denied Edwards's requests. View "In re Edwards" on Justia Law

The case revolves around Gabriel Mirabal, a prisoner at a federal correctional institution in Victorville, California, who was convicted of two counts of assaulting a federal officer resulting in bodily injury. The incident occurred when Mirabal and another inmate, Erik Rojo, passed through metal detectors after lunch. A dispute arose over which inmate wore a white shirt and which wore a brown shirt, as the color of the shirt was linked to the initiation of the assault. The government consistently portrayed Mirabal as the person in the white shirt, while Mirabal maintained that he was clad in brown. Mirabal's defense was predicated upon the theory that he acted in self-defense, a theory that was practically unavailable to the white-shirted individual who joined the fight after it started.In the lower courts, the government filed a motion in limine to exclude the original factual basis under Federal Rules of Evidence 401, 403, and 802. The district court granted the government’s motion, reasoning that the original factual basis constituted inadmissible hearsay. The court held that Rule 801(d)(1)(A)’s hearsay exclusion for prior inconsistent statements did not apply to the original factual basis because Rojo was not called to testify at Mirabal’s trial. And it reasoned that Rule 801(d)(2)’s hearsay exclusion for an admission of a party opponent did not apply to the “opinion” of a prosecutor.In the United States Court of Appeals for the Ninth Circuit, the court held that the district court abused its discretion in excluding the sworn statement of a government attorney as hearsay at Mirabal’s trial. The court stated that in a criminal case, the sworn statement of a government attorney in a plea agreement or sentencing memorandum is a party admission, excluded from the definition of hearsay under Federal Rule of Evidence 801(d)(2). The court further held that the error was not harmless. As a result, Mirabal’s conviction was vacated and the case was remanded for further proceedings. View "USA V. MIRABAL" on Justia Law

Randall J. Weddle was involved in a major motor vehicle accident in Washington, Maine, which resulted in the death of two drivers. The accident involved five vehicles, one of which was engulfed in flames. Weddle, the driver of a large tractor trailer, was found to be the cause of the accident. Hospital tests revealed that Weddle had alcohol in his system and officers found a three-quarters-full whiskey bottle and a shot glass in his truck several days after the accident.Weddle was charged with two counts of manslaughter, two counts of aggravated criminal operating under the influence, one count of causing injury while operating under the influence, one count of aggravated driving to endanger, one count of driving to endanger, and eight counts of violating commercial motor carrier operator rules. The jury found Weddle guilty of all counts. The court conducted a sentencing analysis and set the basic sentence at twenty years, considering the nature and circumstances of the crime. The court set the maximum sentence at thirty years, weighing mitigating and aggravating factors. The final sentence was set at thirty years, with all but twenty-five years suspended, followed by four years of probation.Weddle appealed his sentence to the Maine Supreme Judicial Court. He argued that his sentence was unconstitutional because it was not proportioned to the offense and that it was excessively harsh. The court affirmed the sentence, concluding that the sentence was not greatly disproportionate to the offense and did not offend prevailing notions of decency. The court also found that the sentence was not excessively harsh, as the court had considered both aggravating and mitigating factors in setting the maximum sentence. View "State of Maine v. Weddle" on Justia Law

Deangelo Evans, a passenger in a car pulled over for traffic violations, was subjected to a pat-down search by the United States Park Police officers during the stop. The search revealed a firearm in his waistband, leading to his arrest and subsequent charge for being a felon in possession of a firearm. Evans moved to suppress the firearm as evidence, arguing that it was obtained through an unlawful search. The district court denied his motion, ruling that the pat-down search was justified due to the bulge in his pants that the officers believed might be a gun.The case was tried in the United States District Court for the District of Columbia, where Evans was convicted following a stipulated trial. He preserved his right to appeal the district court's denial of his motion to suppress the firearm as evidence.The case was then brought before the United States Court of Appeals for the District of Columbia Circuit. The court reviewed the district court's findings of fact for clear error. The sole issue on appeal was whether the district court erred in crediting the police officers' testimony that they initiated a Terry frisk only after they saw a bulge in Mr. Evans’s pants that they believed might be a gun. Evans argued that the officers' testimony was inconsistent and implausible. However, the appellate court found that the inconsistencies Evans identified were not so glaring that the police officers' testimony must be a fabrication. Therefore, the court affirmed the district court's decision, ruling that the protective pat-down search was justified and the firearm was admissible as evidence. View "USA v. Evans" on Justia Law

Austin Stryker was convicted for malice murder and other crimes related to the shooting and stabbing death of Hannah Bender. Stryker was a member of a small gang, and the prosecution argued that he killed Bender because he suspected she was informing on the gang's activities. Stryker was charged with multiple counts, including malice murder, felony murder, aggravated assault, aggravated battery, possession of a firearm and knife during the commission of a felony, violating the Street Gang Terrorism and Prevention Act, concealing the death of another, and tampering with evidence. The jury found him guilty on all counts, and he was sentenced to life in prison without the possibility of parole for malice murder, along with consecutive sentences for other charges.Stryker appealed his convictions, arguing that the trial court violated his constitutional right to present a complete defense when it prevented his counsel from making a closing argument that co-defendants Issac Huff and Dylan Reid would have faced minimum sentences of life in prison had they not pled guilty. He also contended that the prosecutor personally attacked his defense counsel in closing argument and that the trial court erred in failing to charge the jury on “grave suspicion” after the prosecutor allegedly misconstrued the beyond-a-reasonable-doubt standard in closing arguments.The Supreme Court of Georgia affirmed Stryker's convictions, concluding that his claims failed. However, the court identified merger errors in Stryker’s sentencing that required correction, and thus vacated part of the judgment. View "STRYKER v. THE STATE" on Justia Law

Diante Thompson was convicted for malice murder and other crimes related to the stabbing death of Bobby Jermaine Ricks. Thompson, along with Demarco Draughn, Benny Hayward, and Xavier Levatte, were charged with malice murder, felony murder, and aggravated assault. Thompson's trial was severed from his co-indictees, who were also convicted of malice murder. The jury found Thompson guilty on all charges and he was sentenced to life in prison without the possibility of parole for malice murder. The felony-murder count was vacated by operation of law. Thompson filed a motion for a new trial, which was denied by the trial court.Thompson appealed his convictions, arguing that the evidence presented at trial was constitutionally insufficient to sustain his convictions and that the trial court erred by failing to grant a new trial. He also argued that the State committed reversible error in its closing argument by telling the jury that it needed to adjudicate the guilt of Thompson’s co-indictees, who were tried separately, and by allegedly shifting the burden of proof to Thompson. Additionally, Thompson argued that his trial counsel was constitutionally ineffective for failing to object to the same allegedly improper statements made by the State.The Supreme Court of Georgia affirmed Thompson’s convictions. The court found that the evidence at trial was sufficient to uphold Thompson’s convictions. The court also found that Thompson's claims of reversible error in the State's closing argument were not preserved for appellate review because defense counsel failed to object to the prosecutor’s allegedly improper statements at trial. Lastly, the court found that Thompson failed to show that his trial counsel was deficient for failing to object to the prosecutor’s allegedly burden-shifting comments. View "THOMPSON v. THE STATE" on Justia Law

The case revolves around Gavin Henderson, who was convicted by a DeKalb County jury for malice murder, cruelty to children in the first degree, and possession of a knife during the commission of a felony. The charges were related to the fatal stabbing of his sister, Kiara Henderson. Henderson was indicted for these charges on September 11, 2018, and found guilty on all counts on July 9, 2021. He was sentenced to life in prison without the possibility of parole for malice murder, among other sentences for the remaining charges. Henderson filed a motion for a new trial, which was denied by the trial court.The case was then brought to the Supreme Court of Georgia. Henderson argued that the trial court erred in admitting prior-acts evidence, failed to charge the jury on the law of voluntary manslaughter, and committed cumulative errors that require reversal. The Supreme Court of Georgia, however, found Henderson's claims of error to be without merit. The court affirmed the trial court's order denying Henderson's motion for a new trial. The court found that the evidence of Henderson's prior violent acts was admissible for purposes of proving his intent, and that there was no evidence to support giving an instruction on voluntary manslaughter. The court also found that Henderson failed to demonstrate any trial court error that would warrant a new trial. View "HENDERSON v. THE STATE" on Justia Law

Richard Stroud Jr. was convicted of felony murder and possession of a firearm during the commission of a felony in relation to the shooting death of Frederick Cade. Stroud and Jarvis Lamont Milton were indicted on multiple charges, including violating the Street Gang Terrorism and Prevention Act, malice murder, felony murder based on aggravated assault, possession of a firearm in the commission of a crime, and aggravated assault. After Milton's case was severed, Stroud was tried before a jury and was acquitted on the malice murder charge but found guilty on the remaining charges. Stroud was sentenced to life in prison with the possibility of parole for the felony murder charge and five years in prison for the firearm possession charge, to run consecutively.Stroud filed a motion for a new trial, which was denied by the trial court. He then appealed his convictions, arguing that the State did not present sufficient evidence to support his convictions beyond a reasonable doubt and that the trial court should have granted his motion for a directed verdict.The Supreme Court of Georgia affirmed Stroud's convictions. The court found that the evidence presented at trial, when viewed in the light most favorable to the jury's verdict, was sufficient to support Stroud's convictions for felony murder predicated on aggravated assault and possession of a firearm during the commission of a felony. The court concluded that even if the jury believed that Milton, and not Stroud, shot Cade, there was ample evidence of Stroud's conduct before, during, and after the shooting for the jury to find Stroud guilty as a party to the crimes because of a shared criminal intent. The court also found that the trial court did not err in denying Stroud's motion for a directed verdict. View "STROUD v. THE STATE" on Justia Law

Jarvis Lamont Milton and Richard Stroud, Jr. were indicted for several crimes, including murder, in relation to the shooting death of Frederick Cade. The case was tried before a jury, and Milton was found guilty on all counts. He was sentenced to life in prison without the possibility of parole for the murder charge and five years in prison for possession of a firearm in the commission of a crime. The other charges were either merged into the murder conviction or vacated. Milton filed a motion for a new trial, which was denied by the trial court.Milton appealed his convictions, arguing that the evidence presented at trial was not sufficient for a rational trier of fact to find him guilty beyond a reasonable doubt. The Supreme Court of Georgia reviewed the case and the evidence presented at trial. The evidence included testimony from witnesses, including the victim's wife and Milton’s girlfriend, as well as physical evidence such as blood samples and a pendant found at the crime scene. The court also considered the conflicting testimonies given by Milton’s girlfriend during the investigation and at trial.The Supreme Court of Georgia affirmed the lower court's decision. The court concluded that the evidence, when viewed in the light most favorable to the verdict, was constitutionally sufficient to support Milton’s convictions for malice murder and possession of a firearm during the commission of a felony. The court stated that even if the jury had concluded that Stroud was the shooter, the evidence was sufficient to find Milton guilty as a party to the crime. The court noted that the jury had the opportunity to assess the credibility of the witnesses and resolve any discrepancies in the evidence presented at trial. View "MILTON v. THE STATE" on Justia Law