Justia Criminal Law Opinion Summaries

The defendant was indicted in the district court on several felony and misdemeanor charges related to a civilian car chase involving gunfire. After indictment and entry of a scheduling order in district court, a police officer obtained two search warrants from the Bernalillo County Metropolitan Court to collect an oral swab and fingerprints from the defendant. Both supporting affidavits failed to disclose the defendant’s indictment and ongoing district court proceedings, and the second warrant was sought while the first was subject to a pending motion to quash in district court.The district court (Second Judicial District Court, Bernalillo County) quashed both warrants and suppressed the evidence, determining that the metro court lacked jurisdiction post-indictment and that the State’s actions violated the defendant’s due process rights. The district court further found that the affidavits were deceptive for omitting material facts about the pending proceedings and that the warrants conflicted with the court’s scheduling order. The suppression was without prejudice to the State seeking the same evidence via a district court motion. The State appealed, and the New Mexico Court of Appeals reversed, holding that the metro court retained authority to issue post-indictment warrants and that omissions in the affidavits did not invalidate the warrants.On certiorari review, the Supreme Court of the State of New Mexico held that metropolitan and magistrate courts retain concurrent authority to issue search warrants after formal criminal proceedings have begun in district court. However, the district court may quash such warrants under its inherent authority to manage its docket and proceedings. The Supreme Court found no abuse of discretion in the district court’s decision to quash the warrants and suppress the evidence, and reversed the Court of Appeals, affirming the district court’s ruling. View "State v. Chavez" on Justia Law

Detectives sought to arrest an individual based on an outstanding warrant and observed him near a corner store. When approached, he fled and discarded a loaded firearm into a bush. Upon apprehension, officers recovered the firearm and found five rocks of crack cocaine and $94 on his person. The individual had multiple prior felony convictions under Louisiana law, including attempted possession of a firearm by a convicted felon, aggravated flight from an officer, possession of heroin, possession of a firearm by a convicted felon, and aggravated battery. He pled guilty to knowingly possessing a firearm after being convicted of a felony.The United States District Court for the Eastern District of Louisiana sentenced him to 70 months of incarceration and three years of supervised release. The court applied a four-level sentencing enhancement under U.S.S.G. § 2K2.1(b)(6)(B), finding that he possessed the firearm in connection with another felony offense, specifically drug trafficking, based on the quantity of crack cocaine and circumstances of his arrest. The defendant objected, arguing there was insufficient evidence to support the enhancement, but the district court overruled the objection and adopted the Presentence Investigation Report.On appeal, the United States Court of Appeals for the Fifth Circuit reviewed his facial and as-applied constitutional challenges to 18 U.S.C. § 922(g)(1), as well as the application of the sentencing enhancement. The court held that existing precedent foreclosed his Second Amendment challenges to § 922(g)(1). Additionally, the Fifth Circuit concluded the district court did not clearly err in applying the four-level enhancement, determining that the record plausibly supported a finding that he possessed the firearm in connection with drug trafficking. Accordingly, the Fifth Circuit affirmed both the conviction and the sentence. View "USA v. McCree" on Justia Law

Late on January 10, 2022, Kansas City police officers stopped a pickup truck with a broken headlight and expired license plate. The driver, Alonzo Miller, was not the vehicle’s owner and could not provide proof of insurance. The officers recognized the area Miller had driven from as one known for criminal activity. During the stop, Miller exhibited nervous behavior. A computer check revealed Miller was on probation and parole for a violent felony involving a firearm. The officers, noting a significant age difference between Miller and his passenger and the late hour, suspected possible illicit activity. After Miller mentioned “something under there” when asked about illegal items and consented to a vehicle search, the officers asked him to step out. Miller behaved unusually, triggering further suspicion. As an officer attempted a frisk, Miller resisted, and a firearm discharged from his coat pocket. Miller was arrested and later indicted for being a felon in possession of a firearm.The United States District Court for the Western District of Missouri denied Miller’s motion to suppress evidence from the stop and search. The magistrate judge found the stop lawful, that Miller’s consent to search was voluntary, and that the officers had reasonable suspicion to extend the stop and frisk Miller based on the totality of the circumstances—including Miller’s criminal history, behavior, and responses during the encounter. The district court adopted these findings. Miller then entered a conditional guilty plea, preserving his right to appeal the suppression ruling.The United States Court of Appeals for the Eighth Circuit reviewed the denial of Miller’s suppression motion, applying de novo review to legal conclusions and clear error review to factual findings. The court held that, under the totality of the circumstances, the officers had reasonable suspicion to extend the stop, request consent to search the vehicle, and frisk Miller. The judgment of the district court was affirmed. View "United States v. Miller" on Justia Law

A law enforcement officer stopped a driver traveling on Interstate 10 in Pinal County, Arizona, suspecting a violation of Arizona Revised Statutes § 28-721(B), which requires drivers moving slower than the normal speed of traffic to use the right lane. The officer had observed the driver operating a 2007 Chevrolet Malibu in the middle lane, slowing below the speed limit, and being passed by another vehicle in the right lane. The officer also noted that the vehicle was newly registered in Nogales, Arizona, and had recently crossed the United States–Mexico border multiple times, fitting a profile for vehicles used in drug trafficking. During the stop, the officer requested a canine sniff, which led to the discovery of fifty-five pounds of marijuana in the trunk. The driver was arrested and charged with possession and transportation of marijuana for sale.Prior to trial in the Superior Court in Pinal County, the defendant moved to suppress the evidence, arguing that the officer lacked reasonable suspicion for the traffic stop. After an evidentiary hearing, the Superior Court denied the motion, finding the stop justified. The jury convicted the defendant, and the court imposed concurrent five-year prison sentences. On appeal, the Arizona Court of Appeals, Division Two, vacated the convictions, holding that the officer lacked reasonable suspicion under § 28-721(B), and concluding that the officer’s interpretation of the statute was overly broad.The Supreme Court of the State of Arizona reviewed the case. It held that the trial court did not abuse its discretion in denying the motion to suppress, because the officer had an objectively reasonable basis for suspecting a traffic violation under § 28-721(B), even if his interpretation of the statute could be debated. The Court clarified the standard for appellate review of video evidence, disapproving State v. Sweeney’s suggestion that appellate courts may independently review such evidence, and reaffirmed that factual findings should be reviewed for reasonable support in the record. The Supreme Court affirmed the trial court’s ruling, vacated the Court of Appeals’ opinion, and remanded for further proceedings. View "STATE OF ARIZONA v ALVAREZ-SOTO" on Justia Law

Two members of the Gypsy Joker Motorcycle Club were prosecuted for their roles in the kidnapping and murder of a former club member. The victim had previously been expelled from the club for theft, severely beaten, and later participated in a robbery at one defendant’s home. In retaliation, the defendants and other associates tracked down the victim, forcibly abducted him, and transported him to a remote location where he was tortured and killed. His body was subsequently found in a field. Both defendants held significant roles in the club, with one serving as chapter president and the other as a full member.Following initial arrests on state charges, federal prosecutors obtained an indictment in the United States District Court for the District of Oregon. The indictment charged both men with murder and kidnapping offenses under the Violent Crimes in Aid of Racketeering (VICAR) statute, kidnapping resulting in death, conspiracy to commit kidnapping resulting in death, and for one defendant, racketeering conspiracy under RICO. Some co-defendants pleaded guilty, but the two appellants proceeded to trial. A jury convicted both on all counts except the racketeering conspiracy charge for one defendant. The district court sentenced each to concurrent life sentences.On appeal, the United States Court of Appeals for the Ninth Circuit affirmed the convictions and sentences. The court held that a VICAR indictment is sufficient if it tracks the statutory language, even without enumerating elements of the predicate state offense. The panel found no error in various evidentiary rulings, including exclusions of certain character evidence and expert testimony, as well as the admission of evidence regarding the club’s nature and culture. The court also upheld the jury instructions on VICAR purpose and consideration of punishment, and rejected an Eighth Amendment challenge to mandatory life sentences, citing binding precedent. View "USA V. DENCKLAU" on Justia Law

The case concerns a criminal defendant charged with murder after an altercation in which the victim, following an argument at his own apartment, was stabbed twice in the back and later died. The defendant claimed self-defense, asserting that he acted to protect himself during a struggle after the victim re-entered the apartment and ended up on top of him. The defendant moved for a pretrial justification hearing under a Utah statute that allows the district court to determine, before trial, whether a defendant’s use of force was justified.The Third District Court held an evidentiary hearing on the defendant’s motion. At that hearing, the defendant provided both a written proffer of facts and attached exhibits, including a preliminary hearing transcript, but did not testify. The district court determined that a mere proffer of facts was insufficient and that the statutory burden required the defendant to present evidence supporting each element of the justification claim. After considering both the proffer and the exhibits, the court found that the defendant’s evidence did not show he subjectively believed the force he used was necessary to defend himself, and thus the court denied the motion to dismiss.On interlocutory appeal, the Supreme Court of the State of Utah addressed the procedural requirements of the pretrial justification statute. The court held that a defendant seeking a pretrial determination of justification must present evidence—rather than mere factual proffers—that, if believed, would be legally sufficient to satisfy each element of the justification defense. The court clarified that this is a burden of production, not a burden of proof. Applying this standard, the court concluded that the defendant failed to produce evidence supporting each element of self-defense and affirmed the district court’s denial of the motion to dismiss. View "State v. Jennings" on Justia Law

A man was charged with solicitation, conspiracy, and attempted murder after allegedly directing three women, with whom he had a polygamous relationship, to kill a fourteen-year-old girl, C.G., and her parents. The motive for the murder plot was to prevent C.G. from testifying in a pending rape case against him. The alleged plan involved the women breaking into the family’s home, but it was foiled when they were discovered, leading to their arrest. The prosecution sought to introduce evidence at trial regarding the rape case involving C.G., the defendant’s prior conviction for raping one of the co-conspirators, and the nature of his relationship with all three women, including his manipulative and coercive behavior.The Third District Court for West Jordan considered the defendant’s motion in limine to exclude this evidence. The court ruled that evidence about the rape case involving C.G. was intrinsic to the current charges, so not subject to Utah Rule of Evidence 404(b), but excluded most details about that case as irrelevant or unduly prejudicial under rules 401, 402, and 403. The court also excluded evidence of the prior rape conviction, finding it irrelevant and inadmissible under 404(b) and 403, and further excluded detailed evidence of manipulation and control over the women as unfairly prejudicial.The Supreme Court of the State of Utah granted the State’s petition for interlocutory review. The court affirmed the exclusion of the prior rape conviction under rule 403, finding its prejudicial effect outweighed its probative value. However, it held that the district court exceeded its discretion in excluding evidence about the rape case involving C.G. and the defendant’s manipulation of the women. The court adopted the rule that acts intrinsic to the charged crime are not “other acts” under 404(b), and found the probative value of this evidence was not substantially outweighed by unfair prejudice. The Supreme Court reversed the exclusions (except for the conviction) and remanded for further proceedings. View "State v. Blackwing" on Justia Law

A woman arrived at a hospital emergency room in the early morning, reporting that she had just been raped nearby. While waiting to be treated, she spoke with a police officer who asked her basic questions about the location, identity, and description of the perpetrator. The woman, visibly distressed and still processing the traumatic event, spontaneously provided additional details about the assault. Later, a Sexual Assault Nurse Examiner (SANE) conducted a medical exam, gathering information to both treat her and document injuries, and recorded the woman's statements about the assault in a standard report. The woman later died from unrelated causes.After the woman’s death, the State charged Arthur Wayne Najera with aggravated kidnapping and aggravated assault. Since the woman could not testify at trial, the State sought to admit her statements to both the officer and the nurse. Najera objected, arguing that admitting these statements would violate his Sixth Amendment Confrontation Clause rights and the rule against hearsay. The Third District Court, Salt Lake County, held several hearings and ultimately admitted both sets of statements, finding them nontestimonial and falling under the excited utterance and medical treatment exceptions to hearsay. Najera then petitioned for an interlocutory appeal.The Supreme Court of the State of Utah reviewed the interlocutory order. It held that the woman’s statements to the officer were nontestimonial because the primary purpose of the interaction was to assess the situation for immediate safety, not to collect evidence for prosecution. Those statements were also admissible as excited utterances. The court further held that the statements to the nurse were primarily for medical treatment under the circumstances and thus were also nontestimonial; they were admissible under the hearsay exception for medical diagnosis or treatment. The court affirmed the lower court’s rulings admitting both sets of statements. View "State v. Najera" on Justia Law

On the night of November 29, 2021, a Hattiesburg police officer conducted a traffic stop of a vehicle due to a defective tag light. The driver, unable to provide identification or insurance, was asked to exit the car. During a protective pat-down, the officer discovered a concealed firearm on the driver, who initially denied its presence. The officer then approached the passenger, Andrew Ducksworth, who stated he was paralyzed from the waist down. After requesting Ducksworth to raise his hands and initiating a pat-down, the officer felt a hard object between Ducksworth’s legs, which Ducksworth denied was a firearm. Upon further investigation and backup, officers found a loaded firearm in Ducksworth’s possession and learned he was a convicted felon.Ducksworth was charged in the United States District Court for the Southern District of Mississippi with being a felon in possession of a firearm under 18 U.S.C. § 922(g)(1). He moved to suppress the firearm, arguing the officer lacked reasonable suspicion for the pat-down, and also moved to dismiss the indictment on Second Amendment grounds. After a hearing, with officer testimony and corroborating body- and dash-cam footage, the district court denied both motions. At a bench trial, Ducksworth stipulated to all elements of the offense, presented no evidence, was found guilty, and sentenced to thirty-six months in prison and three years of supervised release.The United States Court of Appeals for the Fifth Circuit reviewed the denial of the motions and the sufficiency of the evidence. The court held that, considering the totality of the circumstances—including the driver’s possession and concealment of a firearm, the high-crime area, and the officer’s safety concerns—there was reasonable suspicion for the pat-down. The court also held that Ducksworth’s stipulation satisfied the statutory element of a prior felony conviction and rejected his constitutional challenges, affirming the district court’s judgment in full. View "United States v. Ducksworth" on Justia Law

In 1989, Shannon Agofsky robbed a bank in southwest Missouri and kidnapped the bank president at gunpoint, ultimately drowning him in Oklahoma. A federal jury in the Western District of Missouri convicted Agofsky of bank robbery and using a firearm during a crime of violence, resulting in a life sentence. The Eighth Circuit affirmed his conviction, and subsequent motions for collateral relief under 28 U.S.C. § 2255 were denied. In 2001, while serving his sentence in a Texas federal prison, Agofsky murdered a fellow inmate and received a death sentence in the Eastern District of Texas, partly based on his prior firearm conviction.Agofsky later sought to challenge his Missouri firearm conviction by filing a habeas corpus petition under 28 U.S.C. § 2241 in the Southern District of Indiana, arguing—based on the Supreme Court’s decision in Borden v. United States, 593 U.S. 420 (2021)—that bank robbery does not qualify as a “crime of violence” under 18 U.S.C. § 924(c). His claim did not meet the conditions for a successive § 2255 motion. Previously, the Seventh Circuit’s decision in In re Davenport allowed such statutory claims to proceed via § 2241, but the Supreme Court overruled that approach in Jones v. Hendrix, 599 U.S. 465 (2023). Accordingly, the district court dismissed Agofsky’s petition for lack of jurisdiction.On appeal, the United States Court of Appeals for the Seventh Circuit addressed whether § 2255(e) is a jurisdictional bar or merely a venue provision. After reviewing precedent and circuit splits, the court held that § 2255(e) constitutes a jurisdictional limit on the court’s power to entertain habeas petitions outside the strict confines of § 2255. The court affirmed the district court’s dismissal of Agofsky’s § 2241 petition for lack of jurisdiction. View "Agofsky v. Baysore" on Justia Law