Justia Criminal Law Opinion Summaries

A bail bond surety posted a $180,000 bond to secure the release of a criminal defendant. When the defendant failed to appear in court, the Superior Court of San Diego County ordered the bond forfeited and notified the surety. The surety later located the defendant in custody in Texas and informed the district attorney, who chose to extradite the defendant back to San Diego County. The defendant was returned to local custody, and the district attorney sought to recover the costs of extradition from the surety as a condition of exonerating the bond.After the defendant was returned to San Diego, his counsel appeared on his behalf in court pursuant to Penal Code section 977, which allows for appearance by counsel under certain circumstances. The court conditionally exonerated the bond, stating that exoneration was subject to payment of the extradition costs. Subsequent hearings addressed the proper amount of costs and competing motions by the surety to vacate the forfeiture and by the People to recover costs. The Superior Court ultimately denied the surety’s motion and granted the district attorney’s motion, ordering the surety to pay the extradition costs.On appeal, the Court of Appeal, Fourth Appellate District, Division One, held that the defendant’s appearance through counsel was sufficient under Penal Code section 1305, subdivision (c)(1), to require exoneration of the bond. The court further held that conditioning exoneration on payment of actual extradition costs was proper under Penal Code section 1306, subdivision (b), and rejected arguments that the court lacked jurisdiction to order those costs or that the bond was exonerated by operation of law. The appellate court affirmed the lower court’s order, including the award of costs to the People. View "P. v. The North River Ins. Co." on Justia Law

Miguel Angel Santana was charged with several offenses related to a 2016 murder. At his first trial in the Circuit Court for Charles County, a pretrial agreement excluded certain evidence about firearms, ammunition, and marijuana. The jury convicted him on two counts but hung on four others, resulting in a mistrial on those four counts. At the retrial on the remaining counts, a State witness referenced the excluded evidence during testimony, leading Santana’s counsel to move for a mistrial, which the court granted. Before a third trial could begin, Santana moved to dismiss the charges, arguing that Maryland common law should prevent retrial if the State’s reckless conduct caused the mistrial.The Circuit Court for Charles County denied Santana’s motion to dismiss. The court found that the State’s actions did not amount to recklessness, as the prosecutors had prepared the witness for his testimony and did not intend or expect him to reference the excluded evidence. The court concluded that the State's conduct, while unfortunate, was neither intentional nor reckless. Santana appealed, and the Appellate Court of Maryland affirmed the circuit court’s ruling, holding that Maryland’s common law double jeopardy protections did not apply because no factual findings on the criminal charges had been made and, even if the protections did apply, the circuit court’s finding was not clearly erroneous.The Supreme Court of Maryland reviewed the case to consider whether Maryland’s common law double jeopardy prohibition bars retrial after a mistrial caused by reckless State conduct, and whether the State acted recklessly here. The court assumed, without deciding, that Maryland law could bar retrial for reckless conduct, but held that the circuit court’s finding that the State was not reckless was not clearly erroneous. Accordingly, the Supreme Court of Maryland affirmed the judgment of the Appellate Court, permitting retrial to proceed. View "Santana v. State" on Justia Law

Two sixteen-year-old girls ran away from a treatment facility and were taken in by the petitioner, a forty-nine-year-old man, who let them stay at his residence for ten days. During this period, the petitioner provided the girls with drugs, made repeated sexual advances, and sexually assaulted one of them. He later pleaded guilty to attempted sexual assault and distributing a controlled substance to a minor. Based on an evaluation using Colorado's Sexually Violent Predator Assessment Screening Instrument, the district court found that the petitioner met the criteria for a sexually violent predator (SVP) designation and imposed that status at sentencing. The court also sentenced him to fifteen years in prison.The petitioner appealed his SVP designation to the Colorado Court of Appeals, arguing that it constituted cruel and unusual punishment under the Eighth Amendment. The appellate court rejected this argument, relying on precedent holding that the SVP designation was not punishment. The court found no conflict between that precedent and a more recent Colorado Supreme Court decision that found mandatory lifetime sex offender registration to be cruel and unusual punishment as applied to juveniles. The appellate court thus affirmed the district court’s order.The Supreme Court of Colorado granted review to decide whether the SVP designation constitutes criminal punishment under the Eighth Amendment and, if so, whether it is cruel and unusual as applied to the petitioner. The court concluded that the Colorado General Assembly did not intend the SVP designation to be punitive and that its effects did not override that intent by “the clearest proof.” Therefore, it held that the SVP designation and its attendant requirements do not constitute punishment under the Eighth Amendment. The Supreme Court of Colorado affirmed the judgment of the Colorado Court of Appeals. View "Beagle v. People" on Justia Law

A longtime Speaker of the Illinois House of Representatives was prosecuted in federal court for engaging in extensive bribery schemes. The first involved a major utility company, Commonwealth Edison (ComEd), which, facing financial difficulties, funneled more than $3 million to the defendant’s political associates through intermediaries and sham contracts in exchange for the defendant’s legislative support of ComEd’s agenda over several years. The government presented evidence that these payments resulted in concrete legislative actions by the defendant that benefitted ComEd, including support for specific bills and regulatory changes. The second scheme involved the defendant’s agreement to recommend a Chicago alderman for a state board appointment in exchange for business referrals and benefits to the defendant’s family.Following a lengthy trial in the United States District Court for the Northern District of Illinois, the jury convicted the defendant on several counts, including conspiracy, federal-program bribery, honest-services wire fraud, and Travel Act violations. The jury acquitted him on some counts and was deadlocked on others. The district court denied the defendant’s motions for acquittal and for a new trial, then imposed a sentence of imprisonment and a substantial fine.On appeal to the United States Court of Appeals for the Seventh Circuit, the defendant challenged the sufficiency of the evidence and the adequacy of the jury instructions. The Court of Appeals held that sufficient evidence supported each conviction and found no prejudicial error in the jury instructions, including those related to the definition of “official act,” “corruptly,” and the intent elements of bribery. The court also concluded that any potential instructional error regarding state law bribery under the Travel Act was harmless beyond a reasonable doubt. The convictions and sentence were affirmed. View "USA v. Madigan" on Justia Law

The case involved a defendant who, while armed, entered the backyard of a homeowner, shot the resident in the abdomen, and then stole his car. The victim endured extensive medical treatment, including multiple surgeries and physical therapy, and was left permanently injured and unable to work. The defendant was apprehended by police after attempting to flee in the stolen vehicle. During the investigation, he made statements suggesting the shooting was accidental and later provided a similar account during his Presentence Investigation Report interview.The United States District Court for the Western District of Tennessee presided over the case. A grand jury indicted the defendant on carjacking resulting in serious bodily injury and using, carrying, and discharging a firearm during a crime of violence. The defendant pleaded guilty during jury selection. At sentencing, the Presentence Investigation Report declined to apply a two-level reduction for acceptance of responsibility, referencing the timing of the plea and the defendant’s statements minimizing intent. The district court agreed, finding the defendant had not truthfully accepted responsibility and imposed a sentence within the Guidelines, totaling 217 months of imprisonment.On appeal to the United States Court of Appeals for the Sixth Circuit, the defendant argued that the district court erred in not granting the acceptance of responsibility reduction and that his sentence was substantively unreasonable. The Sixth Circuit held that the district court did not clearly err in denying the reduction, given the defendant’s ongoing minimization of his conduct. The appellate court also found the sentence substantively reasonable, as the district court properly considered the relevant sentencing factors and gave no unreasonable weight to any one factor. The Sixth Circuit affirmed the sentence. View "United States v. Simpson" on Justia Law

Arthur Miles was sentenced to a total of 300 months’ imprisonment following two separate federal convictions. After his first sentencing in October 2022, Miles was housed at the Marion County Jail in Indiana for fifteen months—some of this time was before and some after his second federal sentencing. During his time at the county jail, Miles worked as an orderly. He later argued that under the First Step Act of 2018 (“FSA”), he was entitled to earn time credits for this work, which could reduce his sentence, because his federal sentence had commenced and the work was equivalent to an evidence-based recidivism reduction (“EBRR”) program.The United States District Court for the District of Massachusetts reviewed Miles’s habeas petition after a magistrate judge recommended denying the Bureau of Prisons’ (BOP) motion to dismiss. The magistrate judge found that BOP regulations preventing prisoners from earning FSA credits until they arrived at a federal facility conflicted with the FSA’s language. The district court, however, rejected this recommendation and dismissed Miles’s petition, holding that the BOP’s rules did not violate the FSA.The United States Court of Appeals for the First Circuit held that the BOP’s regulation, which delayed the accrual of FSA time credits until a prisoner’s arrival at a federal facility, was invalid because it conflicted with the statutory definition of when a sentence commences. The court further held that a risk and needs assessment is not a prerequisite for earning FSA credits, and that prisoners may earn credits for qualifying programming—such as work as an orderly—performed after sentencing even while housed in non-federal facilities. The court vacated the dismissal of Miles’s habeas petition and remanded for further proceedings to determine his entitlement to credits for his time at the county jail. View "Miles v. Bowers" on Justia Law

The Office of the Attorney General of Maryland initiated a criminal investigation into allegations of child sexual abuse and concealment by clergy and staff of the Archdiocese of Baltimore, based on a 2015 directive from the Governor authorizing the investigation and prosecution of “crimes of exploitation.” The Attorney General’s office issued grand jury subpoenas to the Archdiocese, leading to the production of voluminous records. No indictments were returned, but the Attorney General prepared a report naming over 150 individuals, including some accused of abuse and others alleged to have concealed abuse or failed to act. None of the individuals at issue, the Petitioners, were charged with crimes. The Attorney General sought court authorization to publicly disclose their identities, arguing that public accountability necessitated the release.The Circuit Court for Baltimore City found that the Attorney General had constitutional authority to conduct the investigation and prepare the report, and authorized disclosure of Petitioners’ identities, citing a particularized need for transparency and accountability. Petitioners appealed, and the Appellate Court of Maryland affirmed in part, agreeing that the Attorney General had investigatory authority and could prepare a report, but held that the Circuit Court should have made individualized findings regarding the need to disclose each Petitioner’s identity, and remanded for further analysis.Upon further review, the Supreme Court of Maryland affirmed that the Governor’s directive was within constitutional bounds and that the Attorney General’s office had the authority to investigate and report on child sexual abuse within the Archdiocese. However, the Court held that the interest in public accountability does not create a particularized need sufficient to overcome the secrecy of grand jury materials as to uncharged individuals who object. The Supreme Court of Maryland reversed the Appellate Court’s judgment and directed the Circuit Court to deny the Attorney General’s motion to disclose Petitioners’ identities. View "In Re: Criminal Investn. No. CID 18-2673 Balt. City Circuit Court" on Justia Law

The case centers on Ashantae Corruthers, who, at the request of her friend Regina Lewis, agreed to purchase a firearm for Lewis’s cousin, Darrion Lafayette, in exchange for money. In November 2020, the group traveled from Illinois to Indiana, where Corruthers bought a Glock 48 pistol and ammunition for Lafayette, falsely certifying on the ATF purchase form that she was the true buyer. The firearm was later used by Lafayette in multiple incidents, including the fatal shooting of a police officer in Champaign, Illinois. Afterward, Corruthers falsely reported the firearm as stolen and made misleading statements to federal agents regarding her involvement.A federal grand jury indicted Corruthers and Lewis for conspiracy to illegally purchase and transfer a firearm and conspiracy to engage in misleading conduct. Lewis pled guilty and was sentenced to 60 months’ imprisonment on the firearm charge and 102 months on the misleading conduct charge, to run concurrently. Corruthers also pled guilty. In her case, the United States District Court for the Central District of Illinois calculated her guidelines range at 21 to 27 months but imposed an above-guidelines sentence of 48 months, citing the seriousness and consequences of her conduct. The court rejected the government’s argument to apply the higher offense level for obstruction of a murder investigation, finding that the post-shooting inquiry was not a murder investigation.The United States Court of Appeals for the Seventh Circuit reviewed both Corruthers’s appeal of her sentence and the government’s cross-appeal. The court held that the district court did not abuse its discretion by imposing an above-guidelines sentence, as it fully considered the relevant factors and provided adequate justification. It also affirmed the district court’s refusal to apply the higher guidelines for obstruction, finding no clear error in its determination of the investigation’s scope. The sentence was affirmed. View "USA v. Corruthers" on Justia Law

In August 2023, an adult defendant began communicating over the Whisper social media app with an individual he believed to be an adult, but who was actually thirteen years old. The two exchanged frequent communications, including explicit text, audio, and video messages, and spoke regularly over the course of several weeks. The defendant claimed he thought the other party was an adult, based on her representations, and that any mention of a younger age was part of a roleplay scenario. The communications were discovered when the minor’s classmates alerted school officials, leading to law enforcement intervention and the defendant’s indictment for coercion or enticement of a minor.The case proceeded to trial in the United States District Court for the Northern District of Oklahoma. A jury found the defendant guilty after less than forty minutes of deliberation, and he was sentenced to 140 months in prison. During closing arguments, the prosecutor made remarks suggesting the defendant’s presumption of innocence had been removed by the evidence, and reinforced this with a visual presentation, but the defense did not object at the time. The jury was instructed on the presumption of innocence only at the start of trial, and no specific curative instructions were given after the prosecutor’s statements.The United States Court of Appeals for the Tenth Circuit reviewed the case under plain error analysis, given the lack of objection at trial. The court held that the prosecutor’s statements during closing argument constituted a clear and obvious error that infringed the defendant's constitutional right to the presumption of innocence. The court found the error affected the defendant’s substantial rights, given the context and timing of the remarks, the absence of overwhelming evidence, and insufficient curative instructions. The conviction was vacated and the case remanded for further proceedings. View "United States v. Petro" on Justia Law

The case involves a fatal shooting that occurred during an attempted marijuana purchase in Providence, Rhode Island. The defendant accompanied a friend to buy marijuana from the decedent, who required purchasers to provide identification. The defendant entered the decedent’s car with a firearm, allegedly for protection, and a struggle ensued inside the vehicle. During the altercation, the firearm discharged, resulting in the decedent’s death. The defendant claimed that the shooting was accidental and that he acted in fear during the struggle. After the incident, the defendant returned to his friend’s car and left the scene.The Superior Court conducted a jury trial in which the defendant was convicted of second-degree murder, discharging a firearm while committing a crime of violence, and carrying a pistol without a license. The defendant moved for a new trial, arguing that the verdict was against the weight of the evidence and that the trial justice made errors, including factual misstatements about his role in the events and reliance on facts not in evidence. The trial justice denied the motion, finding the jury’s verdict justified and crediting prosecution witnesses, but mistakenly referred to the defendant as a drug dealer and seller, which was not supported by the record, and referenced evidence not presented at trial.The Supreme Court of Rhode Island reviewed the appeal. It found no error in the exclusion of certain testimony under the State v. Harnois line of cases. However, the Supreme Court determined that the trial justice’s mischaracterization of the defendant’s role and reliance on facts outside the evidence constituted clear error. The Supreme Court vacated the order denying the motion for a new trial and remanded the case for a new hearing on the motion for a new trial in the Superior Court. View "State v. Garcia" on Justia Law