Justia Criminal Law Opinion Summaries

The defendant was originally sentenced in 2005 to a 10-year prison term for assault with a deadly weapon, with additional time added for inflicting great bodily injury, personal use of a weapon, and three prior prison commitments. Nearly two decades later, the defendant sought recall and resentencing under Penal Code section 1172.75, which invalidates certain prior prison term enhancements. However, by this time, the defendant was no longer serving the original sentence that included the enhancements; instead, he was incarcerated for offenses committed while in prison, with those sentences running consecutively to the original term.After the California Department of Corrections and Rehabilitation identified the defendant as potentially eligible for relief, the Superior Court of Riverside County examined whether he qualified under section 1172.75. The court found, based on the defendant’s record, that he had completed the sentence containing the prior prison term enhancements and was now serving time solely for in-prison offenses. Relying on People v. Escobedo, the court concluded that section 1172.75 only applies to individuals currently serving a sentence that includes the now-invalidated enhancements, and not to those serving subsequent, separate sentences for in-prison offenses. The court also rejected the defendant’s equal protection argument, finding a rational basis for the legislative distinction.The California Court of Appeal, Fourth Appellate District, Division Two, affirmed the lower court’s decision. The appellate court held that eligibility for resentencing under section 1172.75 is limited to defendants currently serving a sentence that includes a prior prison term enhancement. Because the defendant was serving a sentence for in-prison offenses, not the original judgment with the enhancements, he was ineligible for relief. The court also found no equal protection violation in the statutory scheme. View "People v. McKean" on Justia Law

Three siblings, all under the age of 14, lived with their father across the street from the defendant between 2015 and 2017. During this period, the children frequently played with the defendant’s children. In 2021, after moving in with a legal guardian due to their father’s poor health and subsequent death, the siblings disclosed that the defendant had repeatedly sexually abused them over a prolonged period. The abuse included acts of sexual intercourse, sodomy, and oral copulation, often accompanied by threats involving firearms. The defendant was charged with multiple counts of continuous sexual abuse of a child, sexual intercourse or sodomy with a child 10 years of age or younger, and oral copulation or sexual penetration with a child 10 years of age or younger.A jury in the Lake County Superior Court found the defendant guilty on all nine counts and found true the multiple-victim allegation. The defendant was sentenced to 75 years to life in prison, with sentences on the remaining counts stayed. On appeal to the California Court of Appeal, First Appellate District, Division Three, the defendant argued that Penal Code section 288.5 was unconstitutional under the Sixth Amendment’s jury unanimity requirement as interpreted in Ramos v. Louisiana, and also challenged the jury instructions regarding unanimity.The California Court of Appeal, First Appellate District, Division Three, held that section 288.5 does not violate the Sixth Amendment’s jury unanimity requirement. The court reasoned that the statute requires unanimity as to the continuous-course-of-conduct element, even if jurors may disagree on the specific acts constituting that conduct. The court also found the jury instruction claim forfeited, as the instructions given were accurate and did not affect the defendant’s substantial rights. The judgment was affirmed. View "People v. Hill" on Justia Law

The petitioner, who was previously sentenced to death in Ohio, obtained a conditional writ of habeas corpus from the United States Court of Appeals for the Sixth Circuit, which required the State of Ohio to conduct a new penalty-phase proceeding within 180 days or have the death sentence vacated. The state failed to meet this deadline, even after receiving several extensions due to complications such as judicial recusals, defense preparations, and questions regarding the petitioner’s competency. As a result, the United States District Court for the Northern District of Ohio converted the conditional writ into an unconditional writ, ordering the state to vacate the death sentence and release the petitioner within five business days. The state did not fully comply until nearly three months later, when the state court formally vacated the sentence.After the state’s delayed compliance, the petitioner moved for relief from the unconditional writ, seeking as a sanction an order barring the state from reprosecuting the death penalty. The district court denied this request, finding that although there were significant delays, many were attributable to the petitioner, and the state’s conduct did not rise to the level of bad faith or substantial inequitable conduct that would justify barring reprosecution.On appeal, the United States Court of Appeals for the Sixth Circuit held that it had jurisdiction to review both the unconditional writ and the denial of the Rule 60(b) motion for sanctions, even after the state’s eventual compliance. The court affirmed the district court’s judgment, holding that the delays and procedural complications did not constitute extraordinary circumstances or substantial inequitable conduct warranting a bar on reprosecution of the death penalty. The court also found no abuse of discretion in the district court’s denial of further relief under Rule 60(b). View "Allah-U-Akbar v. Bradshaw" on Justia Law

The defendant pled guilty in 2016 to conspiracy to possess with intent to distribute controlled substances, receiving a sentence of 160 months based on his criminal history and offense level. In 2023, a retroactive amendment to the Sentencing Guidelines reduced his criminal history category, lowering his guideline range. The defendant, through appointed counsel, and the government stipulated to a new recommended sentence of 144 months, which the district court imposed.After resentencing, the defendant filed a pro se motion for reconsideration, asserting that his counsel had agreed to the stipulation without his knowledge or consent and that he wished to argue for a lower sentence. The United States District Court for the Eastern District of Michigan denied the motion, reasoning that because the defendant was represented by counsel, his pro se filing constituted improper hybrid representation. The court instructed that any motion for reconsideration should be filed through counsel.On appeal, the United States Court of Appeals for the Sixth Circuit held that when a defendant raises a specific and serious allegation that counsel acted without his knowledge or against his wishes on a fundamental matter, the district court is obligated to inquire into the nature of the attorney-client relationship, regardless of whether the defendant used “magic words” or filed through counsel. The Sixth Circuit found that the district court erred by denying the motion solely on the basis of hybrid representation without conducting such an inquiry. The court vacated the district court’s judgment on the motion for reconsideration and remanded for further proceedings, instructing the district court to determine whether the defendant wishes to dismiss his counsel and whether he is entitled to do so, and then to address the merits of his motion. View "United States v. Riley" on Justia Law

In 2009, a defendant was sentenced to an indeterminate term of 28 years to life under California’s original Three Strikes law after his third felony conviction, which was not classified as serious or violent. He also received three one-year enhancements for prior prison terms. In 2012, California voters passed the Three Strikes Reform Act (Proposition 36), which limited indeterminate life sentences to cases where the third strike was serious or violent, and allowed those serving indeterminate sentences for nonserious, nonviolent felonies to petition for resentencing, subject to a discretionary public safety determination by the court.After the Reform Act, the defendant petitioned for resentencing under section 1170.126, but the Santa Barbara County Superior Court denied the petition, finding his release would pose an unreasonable risk to public safety. The California Court of Appeal affirmed this decision. In 2021, the Legislature enacted Senate Bill No. 483, which retroactively invalidated certain prior prison term enhancements and required courts to recall and resentence affected defendants, applying any changes in law that reduce sentences. The defendant sought resentencing under this new law, and the trial court resentenced him to a determinate eight-year term. The Santa Barbara District Attorney challenged this, arguing that the new law unconstitutionally amended the voter-enacted Reform Act by bypassing its public safety requirement. The Court of Appeal agreed and reversed the trial court’s decision.The Supreme Court of California reviewed whether Penal Code section 1172.75, as applied, unconstitutionally amended the Reform Act. The Court held that section 1172.75 must be interpreted to incorporate the Reform Act’s discretionary public safety determination for nonserious, nonviolent third strike offenders seeking resentencing. This interpretation harmonizes the statutes and avoids constitutional conflict, allowing the revised penalty provisions to apply only if the court finds resentencing does not pose an unreasonable risk to public safety. The Court reversed the Court of Appeal and remanded for further proceedings consistent with this holding. View "P. v. Guevara" on Justia Law

The defendant was charged with murder and contributing to the delinquency of a minor after allegedly killing his wife in their home while their two young children were present. Before trial, the prosecution requested that the children be allowed to testify remotely, arguing that testifying in the defendant’s presence would cause them significant emotional distress and impair their ability to communicate. The district court held hearings, received testimony from mental health professionals who had treated the children, and ultimately granted the State’s motion, finding that remote testimony was necessary to prevent serious emotional trauma to the children.The District Court of Cass County, East Central Judicial District, presided over the case. The defendant pleaded guilty to the charge of contributing to the deprivation of a minor, and the murder charge proceeded to trial. The court instructed the jury that the children’s remote testimony was permissible by law and should not influence their deliberations. The children testified via two-way electronic communication, and the jury found the defendant guilty of murder. The court entered a judgment sentencing him to life imprisonment without parole. The defendant appealed, arguing that the district court failed to make the findings required by statute for remote testimony and that his constitutional right to confront witnesses was violated.The Supreme Court of North Dakota reviewed the case. It held that the district court made the necessary findings under North Dakota Century Code § 31-04-04.2(1), specifically that testifying in the defendant’s presence would likely cause the children serious emotional distress or trauma impacting their ability to communicate. The Supreme Court found these findings were supported by the evidence and not contrary to the manifest weight of the evidence. The court concluded that the defendant’s confrontation rights were not violated and affirmed the criminal judgment. View "State v. Moen" on Justia Law

Juan Javier Oquendo was charged with first-degree murder following the fatal shooting of James Cason outside a bar in Pinellas County, Florida. On the night of the incident, Oquendo interacted with several individuals, including his sister and a security guard, before an altercation occurred with Cason near Cason’s car. Witnesses provided conflicting accounts regarding whether Cason or Oquendo produced a gun and how the shooting transpired. Physical evidence indicated multiple shots were fired, and Cason died from a gunshot wound to the head. After the incident, Oquendo fled and later admitted to another individual that he had shot someone. At trial, Oquendo claimed the gun discharged accidentally during a struggle, and the jury was instructed on self-defense.The Circuit Court for Pinellas County denied Oquendo’s request to present expert testimony from a psychologist regarding his post-traumatic stress disorder (PTSD), finding the evidence irrelevant to the self-defense claim and potentially confusing to the jury as diminished capacity evidence. The jury acquitted Oquendo of first-degree murder but convicted him of manslaughter with a firearm. The Second District Court of Appeal affirmed the conviction, holding that PTSD evidence was categorically irrelevant to self-defense under Florida’s objective reasonable person standard, and certified conflict with the First District Court of Appeal’s decision in State v. Mizell, which had allowed limited PTSD evidence in support of self-defense.The Supreme Court of Florida reviewed the case to resolve the conflict. It held that Florida’s self-defense standard contains both a subjective component—what the defendant actually believed—and an objective component—what a reasonably prudent person would believe. PTSD evidence may be relevant to the subjective component but not the objective one. Nevertheless, the Court found no reversible error in excluding the PTSD testimony in Oquendo’s case and approved the Second District’s affirmance of his conviction. View "Oquendo v. State of Florida" on Justia Law

Jonathan Guthmiller was convicted of failing to register as a sexual offender, a requirement stemming from his 2017 guilty plea to luring a minor by computer. Under North Dakota law, he was obligated to register twice yearly and to update his registration within three days of any change in his phone number. In September 2024, Guthmiller was charged for failing to register a valid phone number and for not completing his August 2024 registration.The case was tried in the District Court of Grand Forks County, Northeast Central Judicial District. Before trial, the State proposed jury instructions that did not include the location of the offense as an essential element, citing State v. Samaniego. Guthmiller did not submit alternative instructions or object to the State’s proposal. At a status conference, the court explained the instructions to Guthmiller, who confirmed his understanding and explicitly stated he had no objection. Guthmiller represented himself at trial and did not move for acquittal. The jury found him guilty.On appeal to the Supreme Court of the State of North Dakota, Guthmiller argued there was insufficient evidence to support his conviction, specifically contending the State failed to prove the conduct occurred in Grand Forks County or North Dakota. He also challenged the jury instructions for omitting the location element. The Supreme Court held that Guthmiller had waived any objection to the jury instructions by affirmatively agreeing to them at trial. As a result, the instructions became the law of the case, and the State was not required to prove the location of the offense. The Court found sufficient evidence supported the jury’s verdict and affirmed the criminal judgment. View "State v. Guthmiller" on Justia Law

On December 25, 2022, Nathaniel Fort and his brother, Tarus Walker, went to Aaron Bruce’s apartment to confront him over an alleged assault involving Walker’s child. Walker was armed with an AK-47 rifle, and Fort carried two .40-caliber handguns. After Bruce left his apartment and joined his cousin, Patrick Ross, to discuss the matter, Walker shot Bruce, who fell to the ground. Fort then fired multiple shots into Bruce as he lay on the ground. The two men fled the scene in a vehicle matching the description of Fort’s mother’s car. Police recovered .40-caliber shell casings and bullets near Bruce’s body, and Bruce died at the scene from multiple gunshot wounds.The case was tried in the Miller County Circuit Court. During trial, the prosecution sought to admit Bruce’s autopsy report after the medical examiner who performed the autopsy became unavailable due to illness. Fort objected, arguing that the report required proper attestation and a supporting witness for admission. The circuit court overruled the objection, finding that Fort had waived his right to cross-examine by not subpoenaing a medical examiner or filing a notice of intent to cross-examine. The autopsy report was admitted, and Fort was convicted of capital murder and sentenced to life imprisonment.On appeal to the Supreme Court of Arkansas, Fort challenged the admission of the autopsy report, the denial of his right of allocution, and the sufficiency of the prosecutor’s short report of circumstances. The Supreme Court of Arkansas held that the circuit court erred in admitting the autopsy report without proper attestation, but found the error harmless due to overwhelming evidence of guilt and the cumulative nature of the report. The court also held that Fort’s allocution and report objections were unpreserved for appeal. The conviction and sentence were affirmed. View "FORT V. STATE OF ARKANSAS" on Justia Law

A police officer responded to a report of a car accident in a residential area during the early morning hours and found a vehicle partially in a yard, facing the wrong direction. The officer approached the vehicle and saw Ambreia Washington in the driver’s seat, with a handgun visible on the front passenger seat. After asking Washington to exit the vehicle, the officer inquired whether Washington was a convicted felon, to which Washington replied affirmatively. When Washington attempted to flee, the officer used a taser and placed him under arrest, seizing the handgun. Washington was indicted for unlawful possession of a firearm by a convicted felon and other charges.Washington moved to suppress both the handgun and his statement regarding his felony status. The Circuit Court for Madison County suppressed the statement due to a Miranda violation but denied the motion to suppress the handgun, finding it was properly seized under the plain view doctrine. At trial, Washington was convicted by a jury. On appeal, the Tennessee Court of Criminal Appeals affirmed the trial court’s rulings, concluding that the officer’s actions were justified under the community caretaking doctrine and that the seizure of the handgun was permissible under the plain view doctrine.The Supreme Court of Tennessee reviewed whether the officer’s warrantless seizure of the firearm was lawful. The court held that the seizure was constitutionally permissible under the plain view doctrine, even though the officer’s probable cause to seize the gun was based on Washington’s unwarned but voluntary admission of his felony status. The court clarified that such nontestimonial evidence derived from a voluntary but un-Mirandized statement need not be suppressed absent coercion. The judgment of the Court of Criminal Appeals was affirmed. View "State v. Washington" on Justia Law