Justia Criminal Law Opinion Summaries

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

Three individuals were tried and convicted following a three-week jury trial for their involvement in a violent criminal enterprise. The evidence showed that they were members of a gang operating in northern Virginia and participated in two attempted murders in 2019. One victim was lured into a car, attacked, and left for dead, while another was targeted after surveillance and shot. The defendants played various roles, including driving, surveillance, and assisting in evasion from law enforcement. The charges included racketeering conspiracy, conspiracy to commit murder, drug distribution conspiracy, and, for some, attempted murder, assault with a dangerous weapon, and firearms offenses.The United States District Court for the Eastern District of Virginia presided over the trial. During the proceedings, issues arose regarding the quality of interpretation provided by a court-appointed interpreter, leading the defendants to move for a mistrial. The district court conducted a hearing, found the interpretation errors to be limited and not material, and denied the motion for mistrial. After the trial, the government disclosed unrelated official misconduct by its expert witness on gangs, prompting the defendants to move for a new trial. The district court denied this motion, finding the new evidence was merely impeaching and not material, given the overwhelming evidence of guilt.The United States Court of Appeals for the Fourth Circuit reviewed the case. It held that the interpretation errors did not rise to the level of a constitutional or structural error, as they were isolated and did not render the trial fundamentally unfair. The court also held that the post-trial disclosure regarding the government’s expert witness did not warrant a new trial under Rule 33 or Brady, as it was not material and would not have likely produced a different result. The Fourth Circuit affirmed the district court’s judgment. View "US v. Sandoval" on Justia Law

A federal inmate serving a 210-month sentence challenged the method used by the Federal Bureau of Prisons (BOP) to calculate his good conduct time credits under 18 U.S.C. § 3624(b)(1), as amended by the First Step Act of 2018. The inmate argued that, following the amendments, he should receive a full 54 days of good conduct time credit for the last six months of his sentence, rather than a prorated amount. The BOP, however, interpreted the amended statute to require prorating the credit for any partial year, resulting in the inmate receiving 26 days of credit for the final six months instead of 54.The United States District Court for the District of New Jersey denied the inmate’s habeas petition. The court found that the plain language of the amended statute allowed for proration of good conduct time credits for partial years. As an alternative basis, the District Court also relied on Chevron deference to uphold the BOP’s interpretation. The court rejected the inmate’s additional claims under the Administrative Procedure Act (APA) and the Due Process Clause, finding them either precluded by statute or inapplicable to the rulemaking context.On appeal, the United States Court of Appeals for the Third Circuit reviewed the statutory interpretation de novo. The Third Circuit affirmed the District Court’s judgment, holding that the First Step Act’s amendments, while deleting the word “prorated,” introduced language (“for each year”) that sets a rate of 54 days per year, thereby requiring proration for any partial year. The court concluded that the statute’s natural reading supports the BOP’s method of prorating credits for the last portion of a sentence. The Third Circuit also rejected the inmate’s constitutional and APA-based arguments, and found no basis for applying the rule of lenity. View "Thieme v. Warden Fort Dix FCI" on Justia Law

Edwin Diaz was stopped by law enforcement in Ida Grove, Iowa, after Deputy Clausen observed his truck parked with only one working headlight, broken taillights, and impeding traffic. Upon approaching the vehicle, Clausen smelled marijuana and saw Diaz drop an item later identified as methamphetamine. Diaz and his passenger, Mikaela Breen, were arrested and charged with state drug offenses. Days later, Breen reported to police that Diaz had coerced her into signing a statement taking responsibility for the drugs found in the truck. Based on Breen’s account and Diaz’s criminal history, law enforcement obtained a warrant to search Diaz’s residence, where they found drugs, paraphernalia, and a firearm.The United States District Court for the Northern District of Iowa reviewed Diaz’s motion to suppress evidence from both the truck and home searches. The magistrate judge recommended denying the motion, finding that the truck search was lawful due to probable cause from observed traffic violations and the smell of marijuana, and that the good faith exception applied to the home search despite questions about the warrant’s nexus to the residence. The district judge agreed that the truck search was justified by probable cause and that the good faith exception protected the home search evidence, even though the warrant affidavit did not establish a sufficient nexus between the drugs and Diaz’s home.On appeal, the United States Court of Appeals for the Eighth Circuit affirmed the district court’s denial of the suppression motion. The court held that the initial encounter with Diaz was supported by reasonable suspicion and probable cause due to multiple traffic violations and the odor of marijuana, justifying the truck search. For the home search, the court found that the Leon good faith exception applied because it was not entirely unreasonable for officers to believe that a drug dealer would store contraband at his residence, even if the warrant affidavit lacked a direct nexus. The judgment was affirmed. View "United States v. Diaz" on Justia Law

Anthony Tucker was investigated after child pornography was discovered in a Google Drive account linked to two of his email addresses, one of which he had listed in his sex-offender registration. The investigation revealed that Tucker had previously pleaded guilty in Iowa state court to committing lascivious acts with a child, specifically involving sexual contact with a 13-year-old girl. Based on the evidence found in his Google Drive, Tucker was charged in federal court with possession and receipt of child pornography.The United States District Court for the Northern District of Iowa presided over Tucker’s trial. During the proceedings, the government introduced evidence of Tucker’s prior conviction for lascivious acts with a child. Tucker’s counsel objected to the admission of this evidence, arguing it was unduly prejudicial. The district court overruled the objection, finding the evidence admissible under Federal Rule of Evidence 414, which allows evidence of prior child molestation offenses in cases involving similar charges. The jury ultimately found Tucker guilty on both counts.On appeal, the United States Court of Appeals for the Eighth Circuit reviewed whether the district court erred in admitting evidence of Tucker’s prior conviction. The Eighth Circuit held that Rule 414 permits the admission of evidence of prior acts of child molestation based on the conduct involved, not merely the elements of the prior offense. The court rejected Tucker’s argument that the categorical approach should apply, clarifying that Rule 414 focuses on the specific facts of the prior conduct. The court also found that the district court did not abuse its discretion under Rule 403, as the probative value of the evidence was not substantially outweighed by the danger of unfair prejudice. The Eighth Circuit affirmed the district court’s judgment. View "United States v. Tucker" on Justia Law

A group of individuals planned and executed a robbery of a stash house in Queens, New York, in September 2017. Matthew Elias, one of the defendants, drove a getaway car but was arrested shortly after the robbery, before he received any share of the stolen property, which included marijuana, a gun, and approximately $20,000 in cash. Testimony at trial established that another participant, Hytmiah, kept all the proceeds from the robbery, distributing only a small portion to one other individual and refusing to share with the rest, including Elias.The United States District Court for the Eastern District of New York (Judge Garaufis) presided over the trial, where a jury convicted Elias of Hobbs Act robbery. As part of his sentence, the district court ordered Elias to forfeit $10,000, calculated as a pro rata share of the robbery’s proceeds, under 18 U.S.C. § 981(a)(1)(C). Elias appealed, arguing that the forfeiture order was improper because he never actually acquired any of the proceeds.The United States Court of Appeals for the Second Circuit reviewed the case. The court held that, under 18 U.S.C. § 981(a)(1)(C), as informed by the Supreme Court’s decision in Honeycutt v. United States, criminal forfeiture is limited to property that the defendant personally acquired as a result of the offense. The Second Circuit concluded that Elias was ordered to forfeit property he never obtained, which violated this rule. Accordingly, the court vacated the forfeiture order against Elias. The remainder of the judgments against Elias and his co-defendant were affirmed in part and vacated in part, with instructions for further proceedings consistent with the court’s opinion. View "United States v. Elias" on Justia Law

A seventeen-year-old defendant was charged with murder after the shooting death of a victim in a Bridgeport housing complex stairwell. Surveillance footage showed the defendant leading the victim into the building and exiting alone minutes later, covering his face with a mask. The victim was later found naked and bleeding outside the basement door, having been shot six times. Police investigation led to a search of the defendant’s home, where a .45 caliber pistol and matching ammunition were found in his bedroom. The defendant, interviewed at home in the presence of his legal guardian, admitted to owning the gun and being with the victim but denied involvement in the shooting. Nineteen minutes into the interview, he invoked his right to remain silent, but questioning continued. The defendant was later located in Florida and returned to Connecticut for trial.In the Superior Court for the judicial district of Fairfield, the defendant moved to suppress statements made during the police interview, arguing he had not knowingly and voluntarily waived his Miranda rights. The court found, under the totality of the circumstances, that the waiver was valid, considering the defendant’s age, education, prior experience with law enforcement, and the presence of his guardian. The court suppressed only statements made after the defendant invoked his right to remain silent. The jury convicted the defendant of murder, and he was sentenced to forty-five years’ incarceration.On appeal to the Connecticut Supreme Court, the defendant challenged the validity of his Miranda waiver, sought greater protection under the state constitution, alleged prosecutorial impropriety, and objected to a consciousness of guilt jury instruction. The Supreme Court held that the waiver was knowing, intelligent, and voluntary, declined to adopt a rule requiring consultation with an interested adult before a juvenile’s waiver, found no prosecutorial impropriety, and determined any error in the consciousness of guilt instruction was harmless. The judgment was affirmed. View "State v. Cooper" on Justia Law

In 1984, four women in Connecticut were robbed and sexually assaulted in their homes by an unknown assailant. The perpetrator blindfolded, restrained, and threatened each victim, then stole items before leaving. Police collected physical evidence from the crime scenes, but DNA testing was not available at the time. Years later, advances in forensic science allowed the state laboratory to develop DNA profiles from the evidence, which were uploaded to the Combined DNA Index System (CODIS). In 2020, a private forensic company provided investigative leads, ultimately implicating the defendant. Police lawfully collected trash from the defendant’s residence, including a belt, and submitted it for DNA analysis without a warrant. The DNA extracted from the belt matched the crime scene profiles. Police then obtained a warrant for a confirmatory DNA sample, which further implicated the defendant.The defendant was charged in the Superior Court for the judicial district of Hartford with eight counts of kidnapping in the first degree. At trial, the court instructed the jury on the elements of kidnapping, including the factors from State v. Salamon, which help determine whether restraint exceeded what was necessary for the underlying crimes. The next day, the court provided the jury with a flowchart outlining the kidnapping elements, but the chart omitted reference to the Salamon factors. The jury found the defendant guilty on all counts, and he was sentenced to seventy-two years in prison.On appeal to the Connecticut Supreme Court, the defendant argued that the warrantless collection and analysis of his DNA from the discarded belt violated his rights under the Fourth Amendment and the Connecticut Constitution, and that the omission of the Salamon factors from the flowchart misled the jury. The Connecticut Supreme Court held that neither the collection nor the analysis of DNA from the discarded belt constituted a search under the Fourth Amendment or the state constitution when performed for identification purposes only. The court also found that the jury was not misled by the flowchart, as the full instructions included the Salamon factors and the jury was properly directed to rely on those instructions. The judgment of conviction was affirmed. View "State v. Sharpe" on Justia Law