Justia Criminal Law Opinion Summaries

A pharmacist in Florida, serving as the pharmacist-in-charge at a pharmacy called NH Pharma, was indicted for conspiracy to commit health-care fraud and several counts of health-care fraud. The indictment alleged that he defrauded Medicare by billing for drugs different than those he dispensed and for prescriptions never filled. The pharmacy’s owner cooperated with the government after pleading guilty to conspiracy. At trial, the prosecution presented evidence that the pharmacist and the owner prepared compounded medications using unreimbursable ingredients while billing Medicare for more expensive, reimbursable ones, and attempted to cover up the discrepancies during audits. There was also evidence, including video and witness testimony, that the pharmacist had stolen about $200,000 in cash from the pharmacy. Three Medicare beneficiaries testified that they never received or believed they were prescribed the medications billed in their names.The United States District Court for the Middle District of Florida admitted evidence of the uncharged cash theft, ruling it was intrinsic to the case. The court also excused a potential defense witness, a part-owner and pharmacy technician, from testifying after she invoked her Fifth Amendment right against self-incrimination, and declined to recommend immunity for her. After a jury found the pharmacist guilty on all counts, he moved for a new trial based on statements made by the pharmacy owner in her own sentencing memorandum, arguing they constituted newly discovered evidence. The district court denied this motion.The United States Court of Appeals for the Eleventh Circuit affirmed the convictions. It held that the district court did not abuse its discretion by denying a new trial because the statements were not new evidence, nor material, nor likely to produce a different result. The appellate court also found no abuse of discretion in admitting the theft evidence, declining to compel witness immunity, and not conducting an in-camera hearing, and rejected constitutional claims raised by the defendant. View "USA v. Beasley" on Justia Law

The case centers on Jessie Glass, whose estranged wife, April, reported to law enforcement that she witnessed a significant quantity of child sexual abuse material on Glass’s phone. April provided specific details about the alleged material, the devices Glass owned, and information for accessing his online accounts. Detective Jason Lowrance investigated April’s claims, which included reviewing her prior allegations against Glass as well as Glass’s history of previous investigations for similar offenses. Some of these earlier investigations had been closed without charges or with findings labeled “[u]nfounded.” Lowrance then prepared affidavits for search warrants to search Glass’s home and electronics, securing evidence of child sexual abuse material.The United States District Court for the Western District of North Carolina denied Glass’s motion to suppress, which argued that Lowrance recklessly omitted information in his warrant affidavits that would have undermined April’s credibility and thus probable cause. The district court found that any omissions were not made with intent to mislead or recklessness, and that the omitted facts would not have altered the probable cause determination. A jury later found Glass guilty on all counts, and the district court sentenced him to fifteen years’ imprisonment and imposed financial penalties.The United States Court of Appeals for the Fourth Circuit reviewed the appeal. It held that Lowrance’s affidavits contained sufficient detail to support probable cause, and that the omitted information about April’s credibility would not have defeated probable cause. The appellate court also rejected Glass’s double jeopardy argument, finding the convictions and sentences were based on distinct conduct. Finally, the court affirmed the district court’s imposition of a $5,000 special assessment, concluding the required statutory considerations were adequately addressed. The judgment was affirmed in all respects. View "US v. Glass" on Justia Law

In this case, the petitioner, a Nevada prisoner sentenced to death, challenged his conviction and sentence based on the claim that the prosecutor impermissibly used peremptory strikes to exclude three Black prospective jurors during jury selection. The underlying facts involve the murder of Ebony Mason in 1994, for which the petitioner was charged after being linked to the crime through witness statements and physical evidence. He was ultimately convicted of murder and related charges after a trial in which three of four Black prospective jurors were excluded by the prosecution.The Nevada Supreme Court reviewed the petitioner’s Batson v. Kentucky claims on direct appeal. It found the prosecutor’s reasons for striking two jurors—Emma Jean Samuels and Angela Smith—were race-neutral, as both had close family members with criminal convictions. The court concluded that, once these two strikes were deemed nondiscriminatory, they did not factor into whether there was a pattern of discrimination, and thus, the exclusion of the first Black juror, Gwendolyn Velasquez, was viewed in isolation, with no prima facie case found. The Nevada Supreme Court therefore did not require the prosecution to provide a race-neutral reason for striking Velasquez.On federal habeas review, the United States Court of Appeals for the Ninth Circuit affirmed the district court’s denial of relief on the Batson claims regarding Samuels and Smith, finding no unreasonable application of federal law. However, the Ninth Circuit held that the Nevada Supreme Court unreasonably applied Batson by excluding from consideration the strikes of Samuels and Smith when assessing whether a prima facie case was established as to Velasquez. The appellate court vacated the denial of relief as to Velasquez and remanded for an evidentiary hearing requiring the State to explain its strike. The court also affirmed the district court’s denial of equitable tolling for additional untimely claims and declined to expand the certificate of appealability. View "DOYLE V. ROYAL" on Justia Law

In early 2023, law enforcement in Sioux City, Iowa, used a confidential informant, MS, to investigate methamphetamine distribution. MS identified AP as a supplier, who, in turn, sourced methamphetamine from a man known as “Arkansas,” believed to be Johnnie A. Cannon. Through three controlled buys, investigators observed Cannon’s involvement: he was seen at AP’s residence during each transaction, and physical evidence—including serialized cash from a controlled buy—was seized from him. During a post-arrest interview, Cannon admitted to distributing methamphetamine, including to AP.The United States District Court for the Northern District of Iowa presided over Cannon’s trial. Cannon’s counsel made several motions and challenges at trial, including a Batson challenge regarding jury composition, a motion for judgment of acquittal, and motions for a new trial and arrest of judgment. The district court denied these motions. A jury found Cannon guilty of conspiracy to distribute methamphetamine and three counts of distribution and aiding and abetting distribution. The court sentenced him to 262 months’ imprisonment for these convictions and revoked his supervised release from a prior conviction, imposing an additional 37 months.On appeal, Cannon argued before the United States Court of Appeals for the Eighth Circuit that his Sixth Amendment right to a jury drawn from a fair cross-section was violated, that the admission of his prior conviction was improper under Rule 404(b), that there was insufficient evidence to support his convictions, and that he received ineffective assistance of counsel. The Eighth Circuit held that Cannon’s cross-section jury claim lacked evidence of systematic exclusion, affirmed the admission of his prior conviction as relevant under established precedent, found the trial evidence sufficient to sustain the convictions, and declined to consider the ineffective assistance claim on direct appeal. The court affirmed both the convictions and the revocation of supervised release. View "United States v. Cannon" on Justia Law

The defendant was indicted on criminal charges and released on bail. His counsel raised concerns about his competency to stand trial, prompting the trial court to order a competency evaluation as provided by statute. The appointed evaluator, the Office of the Forensic Examiner, informed the court that it could not complete the evaluation within the ninety-day statutory period. The State requested an extension, which the court granted for an additional ninety days. When it became clear that the evaluation would still not be completed on time, the State sought a second extension or appointment of a different evaluator. The court denied the second extension and dismissed the charges, finding that the statutory timeframe was mandatory and permitted only one extension per party.After the trial court (Superior Court) dismissed the case, the State moved for reconsideration, which was denied. The State then appealed, arguing that the statute did not impose a mandatory, jurisdictional deadline for competency evaluations and that dismissal was not required when the deadline was missed, especially if extensions had been granted.The Supreme Court of New Hampshire reviewed the statutory language and found that RSA 135:17, I(a) does not set a mandatory deadline for completion of competency evaluations. The Court reasoned that the statute’s use of “shall” is modified by the phrase allowing either party to request an extension, and nothing in the statute limits the number of extensions a court may grant. Accordingly, the Court held that the trial court was not legally required to deny the State’s second extension request or to dismiss the charges for missing the extended deadline. The Supreme Court of New Hampshire reversed the dismissal and remanded the case for further proceedings. View "State v. Cormiea" on Justia Law

The appellant was charged with multiple serious sexual offenses involving a minor, including first-degree rape, child sexual abuse by a person in a position of trust, and unlawful sexual contact. Prior to trial, his defense counsel raised concerns about his mental health and ability to participate meaningfully in his defense, noting that while the appellant understood the legal process and charges, he appeared unable or unwilling to engage in his own defense. The trial court ordered a psychiatric evaluation, which found the appellant incompetent to stand trial due to his refusal to participate. The parties subsequently agreed that he should undergo a competency restoration program.After completing the restoration program, a second psychiatric evaluation was conducted. This evaluation concluded that the appellant’s condition had improved, finding him able to communicate with counsel and participate in his defense. The Superior Court of the State of Delaware reviewed both evaluations and, after a teleconference with counsel, found the appellant competent to stand trial. The court scheduled trial, during which the appellant’s counsel did not again raise the competency issue. The appellant was convicted by a Superior Court jury of ten offenses and sentenced to 216 years of imprisonment.On appeal to the Supreme Court of the State of Delaware, the appellant argued that the trial court failed to make adequate factual findings in its competency ruling and that the record as a whole did not support the finding of competency. The Supreme Court reviewed the legal standard de novo and factual findings for support in the record, holding that the trial court relied on competent psychiatric evaluations and statements from counsel, satisfying its duty to make and briefly state factual findings. The Supreme Court found the record supported the determination of competency and affirmed the judgment of the Superior Court. View "Castro v. State" on Justia Law

Derrek Arrington was convicted by a jury of assaulting a Park Police officer with a deadly weapon—specifically, using a car to trap and drag the officer before shooting him in the face—and for being a felon in possession of a stolen firearm. He received a 240-month prison sentence for these offenses. After completing his federal sentence, Arrington remained incarcerated because his actions violated parole from a prior armed robbery conviction in D.C. Superior Court, resulting in an additional 11-year sentence.The United States District Court for the District of Columbia originally imposed the 240-month sentence. Years later, after Arrington had served his sentence for the assault and firearm convictions, a different district judge vacated the original sentence and resentenced Arrington, again imposing the 240-month term. The resentencing judge decided to depart upward from the Sentencing Guidelines range of 140-175 months, citing the extreme moral depravity of Arrington’s actions, including the severe and permanent injuries caused to the officer. The judge also referenced Arrington’s criminal history and questioned whether the Guidelines adequately accounted for the felon-in-possession charge.Arrington appealed to the United States Court of Appeals for the District of Columbia Circuit, arguing that the resentencing judge failed to consider his rehabilitation during his incarceration. The court found that, while the judge’s oral remarks could be interpreted as ambiguous, the record did not show that the judge ignored the rehabilitation evidence. The appellate court held that any error was not plain and that the upward variance was justified by the egregious nature of the conduct. The court also determined that any error regarding consideration of the firearm conviction was harmless. Therefore, the judgment of the district court was affirmed. View "USA v. Arrington" on Justia Law

A police officer responded to a complaint of littering at a McDonald’s parking lot in DeFuniak Springs, Florida, where he encountered John Thomas in a gray Acura matching the reported description. Thomas admitted to littering, exited his vehicle to pick up the trash, and then returned to the driver’s seat. When asked for identification, Thomas produced a Louisiana driver’s license that appeared false, given the age discrepancy. After confirming with the dispatcher that the license information did not match, the officer attempted to arrest Thomas, who resisted, pepper-sprayed the officer, and fled. Thomas abandoned his car nearby and was later apprehended. Police obtained a search warrant for the car, discovering methamphetamine, counterfeit bills, and numerous fraudulent identification documents.The United States District Court for the Northern District of Florida denied Thomas’s motion to suppress the evidence recovered from his car. Thomas argued the warrant was based on information obtained during an illegal stop, asserting that Florida law does not permit officers to detain someone for a noncriminal violation such as littering. The district court found the initial stop lawful, reasoning that the officer had authority to detain Thomas based on the littering complaint and to request identification. It further held that the subsequent arrest for providing false identification was supported by probable cause, validating the search warrant and denying suppression.Upon appeal, the United States Court of Appeals for the Eleventh Circuit affirmed the district court’s decision. The appellate court held that the initial encounter was consensual and did not implicate the Fourth Amendment, and that the officer had probable cause to arrest Thomas for possession of a fraudulent driver’s license under Florida law. Therefore, the evidence obtained from the car search was admissible, and Thomas’s conviction was affirmed. View "United States v. Thomas" on Justia Law

Anthony Seigler and his girlfriend, Katrina Fowles, were involved in two incidents in Lake County in early 2023. In the first, they called 911 reporting armed threats to their son and shots fired into their home; responders found Seigler had fired two shots through a bathroom wall while his son was present, but there was no evidence of an actual attack. Both appeared under the influence of drugs. In the second incident, Fowles’s mother reported a burglary at her home by Seigler and Fowles, and Seigler was found with stolen property. Seigler was charged in two separate cases: one for negligent discharge of a firearm, and another for burglary.The Lake County Superior Court repeatedly continued trial dates over several months for reasons including the need for witness availability, discovery issues, and defense counsel’s request for a mental health evaluation of Seigler due to concerns about his mental state and substance abuse. Despite counsel’s continued difficulty communicating with Seigler and attempts to secure a mental health evaluation, such evaluation was never performed. On the day of trial, defense counsel moved for a continuance and filed an application for mental health diversion. The trial court denied both, finding them untimely and inadequately noticed, and proceeded toward trial. Seigler then entered no contest pleas to both charges and was placed on probation.The California Court of Appeal, First Appellate District, Division Two, reviewed the case. It held that the trial court abused its discretion in denying the continuance, particularly given indications that Seigler’s mental health and substance abuse were significant factors and the statutory right to seek diversion before trial or plea. The Court of Appeal reversed the judgment and remanded, directing that Seigler be given a reasonable opportunity to apply for mental health diversion and, if granted and completed, for dismissal of charges; if not, the judgment would be reinstated. View "People v. Seigler" on Justia Law

A law enforcement officer applied for a search warrant based on information provided by a confidential informant, who had a record of reliability and admitted past drug use. The informant reported seeing a quantity of methamphetamine consistent with trafficking at the defendant’s residence within the previous seventy-two hours and stated the defendant kept a continuous supply of narcotics at her home and on her person. The affidavit described the informant’s familiarity with methamphetamine and recounted the informant’s prior accurate tips and participation in controlled drug buys. Based on this affidavit, a magistrate judge issued a search warrant. Officers executing the warrant found methamphetamine and paraphernalia, leading to the defendant's arrest and indictment for possession of methamphetamine and drug paraphernalia.The defendant moved to suppress the evidence in the Twelfth Judicial District Court, alleging that the affidavit failed to show an adequate basis for the informant’s knowledge because it lacked details on quantity, packaging, or observed sales. The district court agreed, referencing a nonprecedential Court of Appeals memorandum opinion, State v. Belknap, and found the affidavit insufficient. The State appealed. The New Mexico Court of Appeals reversed, concluding that the informant’s first-hand observation and demonstrated knowledge of methamphetamine established a sufficient basis for probable cause.The Supreme Court of the State of New Mexico reviewed the case to clarify the standard for establishing probable cause based on an informant’s tip under Article II, Section 10 of the state constitution and Rule 5-211(E) NMRA. The Court held that the affidavit provided a sufficient factual basis for probable cause because the confidential informant’s first-hand observations, combined with demonstrated credibility and knowledge, met the “basis of knowledge” prong. The Supreme Court affirmed the Court of Appeals’ decision to reverse the district court’s grant of the motion to suppress. View "State v. Perea" on Justia Law