Justia Criminal Law Opinion Summaries

In 2007, the plaintiff was convicted by a jury of first degree murder, robbery, and burglary after he drove accomplices to a location where a planned marijuana theft resulted in the victim’s death. The evidence showed he participated in planning and facilitating the crime, and the jury found him guilty under both aiding and abetting and conspiracy theories. The conviction and sentence of 26 years to life were affirmed by the California Court of Appeal. Later, in an uncontested habeas proceeding, the murder conviction was reduced to second degree and the sentence reduced accordingly.Following legislative changes in 2018 that redefined murder under Senate Bill No. 1437 and created a process for retroactive relief, the trial court vacated the plaintiff’s murder conviction under Penal Code section 1172.6 and resentenced him on the remaining charges. Having served more time than the revised sentence required, he was released. The plaintiff then applied to the California Victim Compensation Board, seeking compensation under Penal Code section 4900 for time served beyond his new sentence, arguing he was “innocent” under the current definition of murder.The Board denied his application, finding he did not allege innocence under the law as it stood at the time of his conviction and that his claim did not state a cognizable basis for relief. The Board also relied on a regulation allowing dismissal of such claims without a hearing. The Superior Court of Los Angeles County denied his writ petition challenging both the Board’s decision and the validity of the regulation.The California Court of Appeal, Second Appellate District, affirmed. It held that compensation under section 4900 requires an “erroneous conviction,” and a conviction valid when rendered does not become erroneous due to subsequent legislative changes. The court also upheld the Board’s regulation as consistent with its statutory authority. View "Gardner v. Cal. Victim Comp. Bd." on Justia Law

A New York state prisoner, convicted of several serious offenses and serving a life sentence without parole, filed a federal habeas corpus petition under 28 U.S.C. § 2254, challenging his convictions. The United States District Court for the Northern District of New York denied his petition on the merits and declined to issue a certificate of appealability. The petitioner missed the deadline to appeal that denial and subsequently moved for an extension of time to appeal under Federal Rule of Appellate Procedure 4(a)(5), arguing that his attorney’s staff absences and communication issues with the petitioner constituted “excusable neglect.” The district court denied this motion, finding the reasons provided were, at most, ordinary attorney error, and again denied a certificate of appealability.The petitioner then appealed the district court’s denial of his Rule 4(a)(5) motion to the United States Court of Appeals for the Second Circuit. The government argued, and the court agreed, that before the appeal could proceed, the petitioner was required to obtain a certificate of appealability because the order denying his extension motion was a “final order” under 28 U.S.C. § 2253(c)(1)(A). The petitioner challenged this requirement, but the Second Circuit concluded that its prior precedent remained binding and that the Supreme Court’s decision in Harbison v. Bell did not remove the certificate requirement for orders that conclude the habeas proceeding.The United States Court of Appeals for the Second Circuit held that a certificate of appealability is required to appeal the denial of a Rule 4(a)(5) motion in this context, and it declined to issue such a certificate because no reasonable jurist would find it debatable whether the district court abused its discretion. The appeal was dismissed for lack of jurisdiction. View "Griffin v. LaManna" on Justia Law

In this case, the petitioner was convicted of first-degree murder with special circumstances after he brutally assaulted a woman, set her on fire, and left her to die. The victim survived for ten months before dying from complications related to her injuries. The petitioner had previously pleaded guilty to rape and attempted murder relating to the same incident, but after the victim’s eventual death, he was charged with murder and sentenced to death following a bench trial. His confessions to law enforcement, as well as physical evidence and eyewitness testimony, connected him to the crime.After his conviction and sentence were affirmed by the California Supreme Court, the petitioner filed several state habeas petitions, arguing that his trial counsel was ineffective in various respects during both the guilt and penalty phases. The California Supreme Court denied relief, often adopting the factual findings of a referee appointed to conduct an evidentiary hearing. The referee found trial counsel credible and discounted much of the petitioner’s new evidence as lacking credibility or being recently fabricated. The petitioner then sought federal habeas relief in the United States District Court for the Central District of California. The district court granted relief based on cumulative ineffective assistance of counsel at the guilt phase, finding that trial counsel’s multiple deficiencies prejudiced the petitioner.On appeal, the United States Court of Appeals for the Ninth Circuit applied the deferential standards required by the Antiterrorism and Effective Death Penalty Act. The court concluded that the California Supreme Court had reasonably determined that trial counsel was not deficient in most respects and that any errors did not result in prejudice sufficient to undermine confidence in the outcome. The Ninth Circuit therefore reversed the district court’s grant of habeas relief and remanded for consideration of the petitioner’s remaining claims. View "SCOTT V. BROOMFIELD" on Justia Law

A defendant was initially tried on multiple charges related to a 2016 murder. At the first trial, the parties had agreed to exclude evidence regarding firearms, ammunition, and marijuana found in a search of the defendant’s home, as these items were not relevant. The jury convicted the defendant on some counts but could not reach a verdict on four charges, leading the Circuit Court for Charles County to declare a mistrial on those counts. At the retrial of the remaining charges, a prosecution witness unexpectedly referenced the previously excluded evidence during testimony. The defense objected, moved for a mistrial, and the State did not oppose. The court granted the motion.The defendant later moved to dismiss further prosecution, citing Maryland’s common law prohibition against double jeopardy, and argued that the State’s reckless conduct had prompted the mistrial. The Circuit Court denied the motion, finding that the State’s actions were neither intentional nor reckless. The defendant appealed, but the Appellate Court of Maryland affirmed, holding that Maryland’s common law double jeopardy protections did not apply since no factual findings had been made on the criminal charges at issue, and even if they did, the State’s conduct was not reckless.The Supreme Court of Maryland assumed, without deciding, that Maryland’s common law double jeopardy rule would bar retrial if a mistrial were caused by the State’s reckless conduct. Reviewing the Circuit Court’s factual finding for clear error, the Supreme Court held that there was competent evidence supporting the lower court’s determination that the State was not reckless. As a result, the Supreme Court of Maryland affirmed the judgment of the Appellate Court, allowing the prosecution to proceed. View "Santana v. State" on Justia Law

The case involves a defendant who, in 2020, confronted individuals renting his neighbor’s house through Airbnb by approaching them with a shotgun, using racial slurs, and threatening them. He also left threatening voicemails for the property owner, making explicit references to race. The defendant was charged in two separate cases: one involving the renters (with charges including reckless endangerment and threatening) and another involving the neighbor (with charges including intimidation based on bigotry or bias and harassment). Ultimately, under a plea agreement, the defendant pleaded guilty to reckless endangerment in the second degree, threatening in the first degree (both under the Alford doctrine), and intimidation based on bigotry or bias in the third degree. The remaining charges were nolled.In the Superior Court for the judicial district of New Britain, the defendant entered his pleas. The trial court conducted a plea canvass, accepted the pleas, and later denied the defendant’s motion to withdraw them, in which he argued that the canvass was constitutionally deficient because the court did not specifically confirm that he was knowingly waiving his rights to a jury trial, to confront accusers, and against self-incrimination. On appeal, the Appellate Court affirmed the trial court’s judgment, holding that the plea canvass was sufficient under Boykin v. Alabama, as the record did not presume a waiver from silence and demonstrated the defendant’s understanding of the rights he was waiving.The Connecticut Supreme Court reviewed the case and affirmed the Appellate Court’s judgment. It held that Boykin does not require an express advisement or enumeration of each constitutional right during a plea canvass. Rather, the totality of the circumstances must show that the plea was made knowingly and voluntarily. Here, the defendant’s responses, counsel’s statements, and the overall canvass were constitutionally adequate, though barely so, and the plea was valid. View "State v. Roberts" on Justia Law

The case involved a man who was charged with felony intimidation after an incident at a pre-release center in Helena, Montana. While reporting for a required urinalysis as a condition of probation, the defendant became upset with a staff member, Curt McAlpin, after being told his test was positive and would be reported to authorities. He was accused of threatening to “shoot up” the center if he had a gun, which caused alarm to McAlpin and led to subsequent police involvement. This event also formed the basis for revoking the defendant’s previously suspended sentence for earlier felony violations of an order of protection.Previously, in the First Judicial District Court, Lewis and Clark County, the defendant was convicted by a jury of felony intimidation. The court denied his motions to dismiss for insufficient evidence and for a directed verdict of acquittal. The court also revoked his probation and resentenced him on the prior convictions, giving him credit for certain periods without violations. The defendant was sentenced to consecutive five-year prison terms for the intimidation conviction and the probation revocation. He then appealed both the conviction and the sentence.The Supreme Court of the State of Montana reviewed the consolidated appeals. It held that there was sufficient evidence for a rational juror to convict the defendant of intimidation, the jury instructions were proper or any error was harmless, and the trial court did not abuse its discretion regarding evidentiary rulings. The court found no reversible plain error, no ineffective assistance of counsel on the record-based claims, and no cumulative error. The calculation of elapsed-time credit for the probation revocation was upheld as legal. The Supreme Court affirmed both the conviction and the sentence. View "State v. Strobel" on Justia Law

The appellant was convicted of felony strangulation of a partner or family member after an incident in which she physically assaulted S.R., her romantic partner. During their relationship, the appellant exhibited a pattern of abusive behavior, including emotional and physical abuse, financial control, and threats. The charged offense occurred during a confrontation related to S.R.’s Facebook communication with another person. During this incident, the appellant took S.R.’s phone and, after a struggle, placed S.R. in a chokehold, applying significant weight that caused pain and lightheadedness but did not result in loss of consciousness. S.R. did not immediately report the assault but later confided in her sister, who helped her contact law enforcement. The appellant was subsequently interviewed by detectives, during which her statements about the incident changed multiple times.The First Judicial District Court for Lewis and Clark County initially declared a mistrial due to comments made in the presence of the jury regarding the controlling nature of the relationship. In preparation for the second trial, the court considered the admissibility of evidence of other acts of domestic violence by the appellant. The court ultimately allowed testimony regarding a pattern of abuse and control, excluding only allegations of prior sexual assault as unduly prejudicial, and permitted limited testimony about prior strangulation.The Supreme Court of the State of Montana reviewed whether the District Court abused its discretion by admitting evidence of other acts under Montana Rules of Evidence 403 and 404(b). The Supreme Court held that the evidence was properly admitted for non-propensity purposes, specifically to demonstrate motive, explain the relationship dynamics, and clarify the victim’s behavior and credibility. The Court concluded that the District Court did not abuse its discretion and affirmed the conviction. View "State v. Mann" on Justia Law

In this case, Montgomery County, Maryland, enacted amendments to its County Code in 2021 and 2022 regulating firearms. The amendments expanded the definition of “place of public assembly,” prohibited the possession of firearms (including “ghost guns”) in or within 100 yards of such places, and removed exceptions for state-issued handgun permit holders. The amendments also imposed new restrictions concerning minors’ access to firearms and regulated ghost guns and their components. The petitioners, two businesses and eight individuals, claimed these provisions were preempted by state law, not a valid local law, and amounted to an unconstitutional taking.After removal to federal court and a partial remand, the Circuit Court for Montgomery County ruled in favor of the challengers, finding the county’s provisions preempted by state law, not a local law, and an unconstitutional taking, and issued declaratory and injunctive relief. The Appellate Court of Maryland remanded for further analysis of preemption and takings issues, particularly concerning the expansion of “place of public assembly.”The Supreme Court of Maryland reviewed the case, holding that new issues may only be properly added by amending the complaint, not through summary judgment motions. The Court determined that Criminal Law § 4-209(b)(1) authorizes charter counties to regulate firearms in limited contexts (with respect to minors, law enforcement, and within 100 yards of certain public places), and that this authority was not abrogated by other state preemption statutes. The Court found Montgomery County’s regulation valid for parks, places of worship, schools, libraries, courthouses, legislative assemblies, recreational and multipurpose exhibition facilities, and polling places, but invalid for hospitals, health centers, long-term care, childcare facilities, government buildings as broadly defined, and generalized gatherings. The Court also clarified the scope of local regulation regarding minors and found no unconstitutional taking occurred. The judgment of the Appellate Court was vacated and remanded with instructions for further proceedings consistent with these holdings. View "Engage Armament v. Montgomery Cnty." on Justia Law

Late at night in downtown Raleigh, police were investigating a stolen vehicle when Milton Allen repeatedly interfered with the officers’ work, ignoring their commands and disrupting the scene while riding his bicycle. Allen’s actions, which included impeding traffic and resisting multiple direct orders to leave, led officers to attempt an arrest. During the arrest, Allen resisted and struggled with officers, who eventually subdued him using handcuffs and ankle restraints. While Allen was restrained but still squirming, officers searched two cross-body bags he had been wearing and found firearms, illegal drugs, cash, and related items. Based on these discoveries, Allen was charged with firearm and drug offenses.The United States District Court for the Eastern District of North Carolina reviewed Allen’s motion to suppress the evidence found in the bags. The district court found that the search of the bags was not a lawful search incident to arrest because Allen was already secured and could not access the bags, relying on United States v. Davis and Arizona v. Gant. The court also rejected the government’s argument that the evidence would inevitably have been discovered under established inventory search policies, concluding that the government had not sufficiently demonstrated that the policies were particular enough to limit officer discretion or that the bags would have inevitably been searched.On appeal, the United States Court of Appeals for the Fourth Circuit addressed whether the evidence should have been suppressed. The Fourth Circuit held that the search of Allen’s bags would inevitably have occurred pursuant to standardized inventory search policies of both the Raleigh Police Department and Wake County Detention Center, which required the search of all arrestees’ personal property and limited officer discretion. The Fourth Circuit concluded that the evidence would have been lawfully discovered and thus should not have been suppressed, reversing the district court’s order. View "United States v. Allen" on Justia Law

Aaron Lyons, after being caught with a gun at age eighteen on a Pittsburgh playground, pleaded guilty to possessing an offensive weapon under Pennsylvania law and was sentenced to probation. Following completion of his probation, he was again found with a firearm and subsequently pleaded guilty in federal court to being a felon in possession of a firearm. The court explained to Lyons that his prior conviction made it unlawful for him to possess a gun and that the federal offense carried significant penalties. At the time, prevailing case law did not require the government to prove that Lyons knew of his status as someone previously convicted of a crime punishable by more than one year.After Lyons’s federal conviction, the Supreme Court in Rehaif v. United States clarified that, for a conviction under the relevant statute, the government must prove the defendant knew of his felony status. Lyons filed a motion under 28 U.S.C. § 2255 in the U.S. District Court for the Western District of Pennsylvania, arguing his guilty plea was unknowing since he was not told of the knowledge-of-status element. The District Court dismissed the motion without an evidentiary hearing, ruling that Lyons had procedurally defaulted his claim by not raising it earlier, and that he failed to show actual innocence.The United States Court of Appeals for the Third Circuit reviewed the appeal and affirmed the District Court’s decision. The court held that Lyons’s Rehaif-based argument was not novel enough to excuse procedural default, as the underlying legal theory was reasonably available before Rehaif was decided. Furthermore, the appellate court found the record conclusively established that Lyons knew his status, making an evidentiary hearing unnecessary. The denial of the § 2255 motion was thus affirmed. View "USA v. Lyons" on Justia Law