Justia Criminal Law Opinion Summaries

John Doe, a Native American juvenile and member of the Eastern Shoshone Tribe, was charged in federal court with multiple offenses, including kidnapping a minor on tribal land for the purpose of physical assault. The government filed a six-count juvenile information, and Doe admitted to certain charges, including kidnapping, assault with a dangerous weapon, and provided a factual basis for his admissions. The events occurred in a trailer on the Wind River Indian Reservation, where Doe assaulted two minor victims and instructed one to remain in a closet as he left the scene.The United States District Court for the District of Wyoming held an admission hearing, where Doe, with counsel, admitted to the relevant charges. The court found a sufficient factual basis and conditionally accepted the admissions. After a delinquency hearing, Doe was adjudicated delinquent on several counts and committed to detention and supervision. Following the district court’s judgment, the Tenth Circuit decided United States v. Murphy, which clarified that the “holds” element of federal kidnapping requires proof the victim was detained for an appreciable period beyond that necessary to commit any related offense. Doe appealed, arguing his admission was not knowing or voluntary because he was not informed of this temporal requirement.The United States Court of Appeals for the Tenth Circuit reviewed the case under the plain error standard. The court held that Murphy did not clearly establish the temporal requirement as an essential element of kidnapping, nor did Doe demonstrate that the district court’s failure to inform him of this requirement was a plain error under well-settled law. The court affirmed the district court’s judgment of delinquency. View "United States v. Doe" on Justia Law

In this case, the defendant was charged with the murder of German Carrillo while both were incarcerated in the Santa Cruz County jail in 2019. The prosecution alleged that the murder was committed for the benefit of a criminal street gang, specifically Nuestra Familia, and also charged the defendant with active participation in a criminal street gang. Evidence at trial included expert testimony about the gang’s structure and rules, testimony from former gang members about intra-gang discipline and removals, and details about the circumstances of Carrillo’s death, including surveillance footage and gang communications. The defendant testified about his own gang involvement, his actions during the incident, and his subsequent departure from the gang.The Santa Cruz County Superior Court conducted a jury trial, where the jury found the defendant guilty of murder with special circumstances and found the gang allegations true. The court sentenced the defendant to life in prison without the possibility of parole, imposed a consecutive gang enhancement, and a concurrent sentence for the gang participation count. The court also imposed a parole revocation fine, suspended unless parole was revoked. The defendant appealed, challenging the sufficiency of the gang evidence, the exclusion of certain mental health evidence, the constitutionality of his sentence, and the imposition of the parole revocation fine.The California Court of Appeal, Sixth Appellate District, reviewed the case. The court held that substantial evidence supported the jury’s findings that the murder and predicate offenses provided a non-reputational benefit to the gang, as required by amended Penal Code section 186.22. The court found no reversible error in the exclusion of mental health evidence, determined the sentence was not unconstitutionally cruel or unusual, and upheld the imposition of the parole revocation fine based on statutory requirements. The judgment was affirmed. View "People v. Cortez" on Justia Law

Police responded to a 911 call in Marshfield, Wisconsin, reporting that Jaison Coleman had threatened to kill his wife, Lisa Coleman, and was still inside their home. Officer Jamie Kizer arrived and spoke with Lisa on the porch, asking about the safety of her children and the location of her husband. Lisa hesitated to answer questions about her children’s safety and initially declined to allow the officer inside. After a brief pause, Lisa returned to the doorway, and following further discussion, she agreed to let Officer Kizer and his colleagues enter the home. Once inside, Lisa directed the officers to the children’s location and indicated where Coleman might be. The officers found Coleman, conducted a protective pat down, and learned from the children that Coleman had threatened Lisa with a gun.Based on information obtained during their entry, the officers secured a warrant to search the home, which led to the discovery of several firearms. Coleman was indicted for unlawful possession of a firearm as a convicted felon under 18 U.S.C. § 922(g)(1). He moved to suppress the firearms, arguing that Lisa had not consented to the officers’ entry. A magistrate judge found that Lisa had consented and recommended denial of the motion. The United States District Court for the Western District of Wisconsin adopted the magistrate judge’s findings and denied the suppression motion, also concluding that the officers did not exceed the scope of Lisa’s consent. Coleman pleaded guilty but reserved the right to appeal the suppression ruling.The United States Court of Appeals for the Seventh Circuit reviewed the district court’s findings for clear error. The appellate court held that Lisa’s consent was voluntary and that the officers acted within the scope of her consent. The court affirmed Coleman’s conviction, finding no error in the district court’s rulings. View "United States v. Coleman" on Justia Law

In 1996, Samuel Smithers was hired to maintain a 27-acre property in Plant City, Florida, where two women, Cristy Cowan and Denise Roach, were found murdered near the property’s ponds. Evidence, including DNA and surveillance footage, linked Smithers to the victims. After being questioned by law enforcement, Smithers gave inconsistent statements and ultimately confessed to both murders. At trial, medical testimony established that both victims died from a combination of strangulation and wounds inflicted by a sharp instrument. Smithers testified in his own defense, blaming an unknown man for the crimes, but the jury convicted him of two counts of first-degree murder and unanimously recommended the death penalty for both.The Circuit Court for Hillsborough County sentenced Smithers to death, finding several aggravating factors and weighing mitigating circumstances. The Florida Supreme Court affirmed his convictions and sentences on direct appeal. Smithers subsequently filed multiple postconviction motions and federal habeas petitions, all of which were denied by the respective courts, including the United States Supreme Court’s denial of certiorari. In 2025, after the Governor signed his death warrant, Smithers filed a successive postconviction motion arguing that executing him at age 72 would constitute cruel and unusual punishment due to his advanced age.The Supreme Court of Florida reviewed the summary denial of Smithers’ motion. The court held that his claim was untimely and procedurally barred under Florida Rule of Criminal Procedure 3.851, as none of the rule’s exceptions applied. Additionally, the court concluded that Florida’s conformity clause requires its courts to follow United States Supreme Court precedent, which does not recognize a categorical exemption from execution based on advanced age. Therefore, the Supreme Court of Florida affirmed the circuit court’s summary denial of Smithers’ successive postconviction motion. View "Smithers v. State" on Justia Law

A defendant was convicted of first-degree murder and attempted murder for crimes committed at age 17, alongside an adult codefendant. The jury found true allegations of gang involvement and personal use of a firearm, resulting in an aggregate sentence of 75 years to life, plus additional time for unrelated carjacking offenses. After serving 15 years, the defendant petitioned for recall and resentencing under California Penal Code section 1170(d), arguing that his sentence was the functional equivalent of life without parole and that he met several statutory eligibility criteria, including having committed the offense with an adult codefendant.The Superior Court of Los Angeles County reviewed the petition, held a hearing, and denied relief. The court found that none of the eligibility criteria were satisfied, reasoning that the adult codefendant’s conviction had been vacated under a separate statute and that the defendant had not shown sufficient rehabilitation. The court also considered the defendant’s juvenile record and prison disciplinary history, concluding that he lacked potential for rehabilitation.On appeal, the California Court of Appeal, Second Appellate District, Division Four, reviewed the trial court’s factual findings for substantial evidence and interpreted the statutory language de novo. The appellate court held that the defendant satisfied the criterion of having committed the offense with an adult codefendant, as the adult was charged and convicted for the same incident, even though her conviction was later vacated due to a change in law. The court reversed the trial court’s order denying the petition and remanded the case for a resentencing hearing in accordance with section 1170(d), without expressing an opinion on the appropriate sentence. View "People v. Gomez" on Justia Law

A defendant was charged with multiple sexual offenses, including forcible rape, forcible oral copulation, unlawful sexual intercourse, and incest, all involving a 17-year-old relative. The alleged incident occurred when the defendant stayed overnight at the victim’s home, entered her bedroom, and engaged in sexual acts. The victim testified about the charged offenses and two prior uncharged incidents. The prosecution presented evidence including pretext phone calls, expert testimony on child sexual abuse victim psychology, and testimony from an investigating officer. The defendant denied all wrongdoing and challenged the credibility and admissibility of certain evidence.The case was tried in the Monterey County Superior Court, where the jury convicted the defendant on all counts. The trial court granted the prosecution’s request to modify the pattern jury instructions regarding the definition of “force” for the forcible rape and oral copulation charges. The defendant appealed, arguing that the evidence was insufficient for some counts, that the modified jury instructions were erroneous, and that certain evidence and expert testimony were improperly admitted. He also claimed ineffective assistance of counsel for failing to object to specific evidence and testimony.The California Court of Appeal, Sixth Appellate District, reviewed the case. It held that the trial court erred in modifying the jury instructions to define “force” as including any physical movement or positioning of the victim’s body, which was misleading and prejudicial. As a result, the convictions for forcible rape and forcible oral copulation were reversed and remanded for possible retrial. The court found that other asserted errors were harmless and affirmed the convictions for unlawful sexual intercourse and incest. The court ordered retrial and resentencing on the reversed counts. View "People v. Melgoza" on Justia Law

Federal authorities investigated a man in Michigan after receiving a tip that he was distributing methamphetamine sourced from Las Vegas. Over several months, law enforcement gathered evidence, including intercepting a package containing nearly seven pounds of methamphetamine sent to his uncle’s home. Upon executing search warrants, officers seized drugs, cash, and firearms from both the uncle’s residence and the defendant’s home. The defendant admitted his involvement during a post-arrest interview. After serving a short state sentence for probation violations, he moved to Atlanta, where he was employed and had no further criminal incidents for about a year. In 2023, a federal grand jury indicted him for drug and firearm offenses. He was arrested in Michigan several months later, and while out on bond, he violated conditions and was re-arrested. While in jail, he attempted to smuggle synthetic drugs and was caught with contraband.The United States District Court for the Western District of Michigan denied the defendant a reduction for acceptance of responsibility, citing his continued drug-related conduct and false denials during the presentence investigation. The court also denied his request for a downward variance based on his period of lawful behavior in Atlanta, but did grant a downward variance due to his lack of youthful guidance, sentencing him to 300 months, below the guideline range. Defense counsel did not object to the court’s handling of non-frivolous arguments at sentencing.On appeal, the United States Court of Appeals for the Sixth Circuit reviewed the district court’s denial of the acceptance-of-responsibility reduction for clear error and affirmed, holding that post-offense drug activity and false denials were relevant to assessing acceptance of responsibility under U.S.S.G. § 3E1.1(a). The appellate court also declined to review the procedural reasonableness of the sentence, finding that the defendant had either waived or invited any error by affirming that all arguments had been addressed. The judgment of the district court was affirmed. View "United States v. Jett" on Justia Law

Marian Hudak was charged with two federal hate crimes after separate assaults on two men in North Carolina. The first victim, J.D., was a Mexican-American neighbor whom Hudak had repeatedly harassed with racial slurs and threats, culminating in a physical attack. The second victim, J.S., was a Black man whom Hudak confronted in traffic, using racial epithets and threats, and physically attacked his vehicle before chasing him to his apartment complex and threatening further violence. Evidence showed Hudak possessed Nazi and Ku Klux Klan memorabilia and had a history of expressing racist views.The United States District Court for the Middle District of North Carolina presided over Hudak’s trial. The government presented evidence of Hudak’s racist motives, including testimony about his Nazi memorabilia and prior racist conduct. Hudak conceded intent to injure and intimidate but argued his actions were due to road rage and mental illness, not racial animus. The district court excluded expert testimony about Hudak’s mental illness, finding it unreliable and irrelevant under Federal Rule of Evidence 702 and the Insanity Defense Reform Act, since Hudak did not plead insanity. The court also admitted evidence of Nazi memorabilia after Hudak testified about his interest in military history, determining he had “opened the door” to its relevance.On appeal, the United States Court of Appeals for the Fourth Circuit reviewed the district court’s evidentiary rulings for abuse of discretion. The Fourth Circuit held that the district court properly excluded the mental health evidence and correctly admitted the Nazi memorabilia after Hudak’s own testimony. The court affirmed the jury’s verdict, holding that the government only needed to prove the victims’ race or national origin was a but-for cause of the assaults, and that Hudak received a fair trial. The judgment of the district court was affirmed. View "United States v. Hudak" on Justia Law

The case concerns an incident in which a man, living in a two-bedroom condominium with his long-term partner and their children, was charged with aggravated assault after striking a visitor, M.H., with a microphone stand. The defendant and his partner, J.A., had a history of conflict regarding M.H., who had previously assaulted the defendant and had a felony conviction. On the day in question, after returning home to find M.H. present, the defendant locked himself in his bedroom. J.A. and M.H. forcibly entered the bedroom despite the defendant’s objections, leading to the altercation.The Superior Court in Pima County denied the defendant’s request for jury instructions on the defense of residential structure, defense of premises, and the statutory presumption that force is justified when defending against unlawful entry into a residential structure. The jury convicted the defendant on one count of aggravated assault, and he was sentenced to five years in prison. The Arizona Court of Appeals affirmed the conviction, holding that M.H. was lawfully present as J.A.’s invitee.The Supreme Court of Arizona reviewed the case and held that a separately securable bedroom within a shared residence qualifies as a “residential structure” under Arizona law. The Court further held that the statutory presumption of justified force applies when an uninvited person forcefully enters such a space, even if another resident invited them into the common areas. The Court found that the trial court erred in refusing the requested jury instructions and that this error was not harmless. The Supreme Court of Arizona reversed the conviction, vacated the sentence, and remanded the case for a new trial. View "STATE OF ARIZONA v BROWN" on Justia Law

Justin Cutbank was charged with being a felon in possession of a firearm after an incident in which he, while intoxicated and under the influence of methamphetamine, threatened his girlfriend D.F. with a gun, held her in a closet, and struck her with the weapon. He also involved other residents of the home, including D.F.’s teenage sons and housemate, before fleeing with the gun and D.F.’s cell phone. Police later found Cutbank barricaded in a nearby garage, where he resisted arrest and assaulted an officer. A sawed-off Marlin .22 caliber rifle, matching DNA evidence to Cutbank, was recovered along the route between the two locations.The United States District Court for the District of Minnesota presided over Cutbank’s trial. The jury convicted him of being a felon in possession of a firearm and found he had at least three prior violent felony convictions, triggering enhanced sentencing under the Armed Career Criminal Act. The district court sentenced him to 292 months imprisonment, applying several sentencing enhancements, including a four-level increase for possessing the firearm in connection with another felony offense under USSG § 2K2.1(b)(6)(B).On appeal, the United States Court of Appeals for the Eighth Circuit reviewed Cutbank’s claims of evidentiary and procedural errors, including objections to witness testimony, jury instructions, and the admission of certain statements. The appellate court found no abuse of discretion in the district court’s evidentiary rulings and determined that the sentencing enhancements were properly applied. The Eighth Circuit held that the district court correctly calculated the guidelines range, considered the relevant sentencing factors, and imposed a reasonable sentence. The judgment of the district court was affirmed. View "United States v. Cutbank" on Justia Law