Justia Criminal Law Opinion Summaries

The defendant was convicted by a jury of first-degree felony murder, aggravated burglary, attempted aggravated robbery, two counts of aggravated assault, and criminal possession of a weapon after a 2016 home invasion and homicide. Following a mistrial at his first proceeding, a second trial resulted in convictions on all charges. At his original sentencing, the district court calculated the defendant’s criminal history score as A, in part based on a 2003 criminal-threat conviction, and imposed a life sentence without parole eligibility for 653 months, plus consecutive sentences on the remaining counts.On appeal from the original sentencing, the Supreme Court of Kansas affirmed the convictions but vacated the sentence. The court concluded that the district court erred in including the 2003 conviction in the criminal history score, as the statute under which it was obtained had been found unconstitutional in part by the Supreme Court of Kansas in State v. Boettger, 310 Kan. 800 (2019). The court remanded the case for resentencing with instructions not to include the 2003 conviction. On remand, the district court recalculated the criminal history score as B and resentenced the defendant accordingly, reducing the parole eligibility period and other determinate sentences. The court denied the defense’s renewed motion for a departure sentence.The Supreme Court of Kansas reviewed the appeal from resentencing. The defendant raised, for the first time, constitutional challenges to the Kansas Sentencing Guidelines Act, arguing that it violated his jury trial rights by permitting a judge to determine prior convictions that enhance punishment. The court declined to review these unpreserved claims, finding that settled law foreclosed relief. The defendant’s claim for additional jail credit was rendered moot by a nunc pro tunc order from the district court. The Supreme Court of Kansas affirmed the judgment of the district court. View "State v. Smith " on Justia Law

On July 17, 2022, Printara Jackson was found dead from a gunshot wound at an apartment complex in Kansas City, with Cedrick Scott injured nearby. Scott was transported to the hospital and survived. The State charged Terry Horton with aggravated battery for Scott’s injuries and felony murder for Jackson’s death. The prosecution’s case relied heavily on circumstantial evidence, including surveillance video and testimony from the lead detective, since there were no known eyewitnesses except Scott, who was never interviewed. Witnesses placed Horton at the scene, and video evidence showed a person identified as Horton separating from a group near the location and time of the shooting. The State theorized that Horton shot Scott after a dispute involving his sister, resulting in Jackson’s death during the commission of that crime.The District Court of Wyandotte County presided over the trial. During the proceedings, the court excluded as inadmissible certain hearsay statements attributed to Scott, ruling that they constituted impermissible double hearsay not covered by an exception. Horton was convicted by a jury of first-degree felony murder and aggravated battery and was sentenced to life imprisonment plus a concurrent sentence for the battery charge. He appealed, challenging the exclusion of hearsay evidence, sufficiency of the evidence, alleged prosecutorial error, and cumulative error.The Supreme Court of the State of Kansas reviewed the case. It held that before admitting double hearsay, a statutory exception must apply to each layer of hearsay, and found no error in the trial court’s ruling because Horton had not established an applicable exception at trial. The court also held that sufficient circumstantial evidence supported Horton’s convictions and found no prosecutorial error or cumulative error. The Supreme Court of Kansas affirmed Horton’s convictions. View "State v. Horton " on Justia Law

The case concerns a fatal shooting that occurred in the early morning hours in the Aggieville district of Manhattan, Kansas. The defendant, a 19-year-old, engaged in a verbal altercation with another group after leaving a bar. During the argument, the defendant retrieved a firearm from his vehicle and approached a member of the other group, Joshua Wardi. Despite not seeing Wardi or anyone else with a weapon, the defendant claimed he felt threatened and shot Wardi five times at close range, killing him. The defendant then ran in the same direction as other members of Wardi's group, who fled after seeing the firearm. Police pursued and apprehended him shortly thereafter. At trial, the defendant argued that he acted out of fear but acknowledged that Wardi was unarmed and that his actions were motivated by anxiety.The Riley District Court presided over the trial, where the defendant was convicted by a jury of first-degree premeditated murder, three counts of attempted first-degree murder, and three counts of aggravated assault. The defendant was sentenced to life imprisonment without the possibility of parole for 767 months. He appealed, alleging errors including the denial of requested jury instructions on self-defense and imperfect self-defense, insufficient evidence supporting the attempted murder convictions, improper judicial comments, and cumulative error.The Supreme Court of the State of Kansas reviewed the case. It held that, although instructions on imperfect self-defense and self-defense were legally appropriate, the record did not contain evidence sufficient to make them factually appropriate. Even assuming error in not giving the imperfect self-defense instruction, the court found it harmless beyond a reasonable doubt due to overwhelming evidence against the defendant. The court also determined that the defendant’s confession regarding the attempted murders was sufficiently corroborated. Judicial comment error regarding the mention of the potential life sentence was found to be harmless, particularly since a curative instruction was given. The cumulative effect of any errors did not deny the defendant a fair trial. The Supreme Court of Kansas affirmed the convictions. View "State v. Montgomery " on Justia Law

Mitchell Melega, serving as the financial controller for two companies owned by Erik Jones, participated in a scheme to defraud two regional banks. The companies, involved in vehicle sales and property management, submitted false promises and forged documents to secure loan advances for nonexistent projects or vehicles. Melega played a central role in submitting fraudulent documents, directing employees to hide the scheme, and helping divert the funds for unauthorized purposes. The fraudulent activities spanned over a year and caused more than $7,000,000 in losses to the banks. Both Melega and Jones were indicted on multiple counts, but while Jones entered a plea agreement with a set sentencing range and received 54 months' imprisonment, Melega entered an open plea and proceeded to sentencing without a stipulated range.The United States District Court for the Central District of Illinois calculated Melega’s sentencing range using the 2023 U.S. Sentencing Guidelines, applying a two-level enhancement for the use of sophisticated means and another two-level enhancement for his role as a supervisor in the offense. The court found Melega directly engaged in complex concealment and management of the fraudulent scheme, including instructing others to provide false information. After considering these enhancements and mitigation evidence, the court sentenced Melega to 75 months, a term below the advisory guideline range.On appeal, the United States Court of Appeals for the Seventh Circuit reviewed whether the enhancements were properly applied, whether the court relied on unreliable facts, and whether there was an unwarranted sentencing disparity compared to Jones. The Seventh Circuit held that the district court did not clearly err in applying either enhancement, did not rely on inaccurate or unreliable information, and provided a reasonable basis for the sentencing disparity. The appellate court affirmed Melega’s sentence. View "USA v Melega" on Justia Law

A man residing with his mother was involved in her killing and decapitation in Stone County, Mississippi. The discovery of the crime followed a welfare check initiated by family concerns after they had not heard from the mother. When law enforcement arrived, the defendant initially resisted entry but then permitted officers into the home, where further investigation led to the discovery of the mother's body and head on the property. The defendant later confessed to the killing during both a police interview and a recorded phone call. Evidence showed a history of mental illness, conflict between the defendant and his mother over financial issues, and extensive injuries related to the crime.The Stone County Circuit Court found the defendant incompetent to stand trial at first, but, following psychiatric treatment, later deemed him competent. Before trial, the defense moved to suppress evidence obtained during the initial warrantless search, but the court denied the motion. At trial, the defense presented an insanity defense with expert testimony, while the State offered its own expert in rebuttal. The defendant was ultimately convicted by a jury of first-degree murder and sentenced to life imprisonment. Post-trial motions challenging the weight of the evidence, the denial of certain jury instructions, evidentiary rulings, and restrictions on closing arguments were denied by the trial court.Upon review, the Supreme Court of Mississippi affirmed the conviction and sentence. The court held that the trial court correctly denied lesser-included-offense instructions because the evidence overwhelmingly indicated deliberate design. The court determined the warrantless search was lawful under the inevitable discovery doctrine. Objections to the admission of video evidence and limitations on closing argument were either procedurally barred or, if error, harmless. The jury’s verdict was found not to be against the overwhelming weight of the evidence. View "Johnson v. State of Mississippi" on Justia Law

A man was convicted in 2008 after pleading no contest to rape and other forcible sex offenses committed against a woman at knifepoint. He was sentenced under California Penal Code section 667.6, subdivision (c), to an aggregate term of 50 years in prison, consisting of full, consecutive terms for each offense and a weapon enhancement, pursuant to a plea agreement. After serving 15 years, he received a youth offender parole hearing under Penal Code section 3051, subdivision (b)(1), which allows such hearings for offenders who committed their crimes at age 25 or younger. The victim participated in the hearing to oppose parole, and parole was denied, but a new hearing was set.The victim and a crime victims’ advocacy organization filed a petition for writ of mandate in the Superior Court of Los Angeles County, seeking to block the parole hearing and to prevent enforcement of section 3051 for any prisoner sentenced under section 667.6, subdivisions (c) or (d). They argued that section 3051 was unconstitutional as applied to such offenders because it amended a voter initiative statute (Proposition 83) without the required two-thirds legislative approval or voter approval, in violation of the California Constitution. The superior court assumed the victim had standing but not the advocacy group, and denied the petition, finding that Proposition 83 did not substantively amend section 667.6, subdivision (c).The California Court of Appeal, Second Appellate District, Division Seven, reviewed the case. It held that Proposition 83 made only technical, not substantive, changes to section 667.6, subdivisions (c) and (d), and that the statutory scheme for consecutive sentencing of sex offenses was not integral to the initiative’s goals. Therefore, the enactment of Penal Code section 3051 was not an unconstitutional amendment. The appellate court affirmed the judgment denying the petition. View "Jessica M. v. Cal. Dept. of Corrections & Rehabilitation" on Justia Law

After a car accident, a woman was transported to a hospital for treatment of a head injury. While there, she received medical care, including Fentanyl for pain, and hospital staff performed a blood test that revealed an extremely high blood alcohol content. The hospital, as required by law, reported the test result to police. Later that night, a police officer went to the emergency room to question the woman. The officer informed her of her Miranda rights and asked if she was willing to talk. The officer testified that the woman understood her rights, appeared responsive and coherent, and agreed to speak. During the conversation, the officer asked if she would consent to another blood draw to check her blood alcohol level. The woman agreed, and the test again showed a very high blood alcohol concentration.In the Multnomah County Circuit Court, the woman moved to suppress the statements she made to the officer and the results of the second blood draw. She argued that her statements were not voluntary due to her intoxication and medical condition, and that she was incapable of giving valid consent to the blood test. The circuit court denied both motions, concluding that she had knowingly and voluntarily spoken to the officer and consented to the blood draw. She entered a conditional guilty plea to driving under the influence of intoxicants, reserving her right to appeal.The Oregon Court of Appeals affirmed, holding that the hospital setting was not “compelling circumstances” requiring Miranda warnings, and that the woman voluntarily consented to the blood draw. The Supreme Court of the State of Oregon also affirmed, holding that, under the totality of the circumstances, the woman was not in compelling circumstances during the police questioning and her statements were voluntary. The Court further held that she voluntarily consented to the second blood draw. The holdings were not interdependent, and both lower courts' decisions were affirmed. View "State v. Miller" on Justia Law

The defendant was charged with two counts of unauthorized use of a vehicle after taking two utility trailers without the consent of their owners. At trial, the defendant argued that a trailer does not qualify as a “vehicle” under the relevant Oregon statute, ORS 164.135, which defines the offense of unauthorized use of a vehicle. The trial court, relying on prior case law, denied the defendant’s motion for judgment of acquittal and found him guilty on both counts.The defendant appealed to the Oregon Court of Appeals, contending that the legislature did not intend for utility trailers to be included within the statute’s definition of “vehicle,” and urging the court to overrule its prior decision in State v. Phillips, 315 Or App 178 (2021). The Court of Appeals rejected these arguments, affirmed the convictions, and upheld its construction of the statute.The Supreme Court of the State of Oregon granted review to determine whether a trailer is a “vehicle” for purposes of ORS 164.135. The court examined the statutory text, context, and legislative history. It found that although dictionary definitions of “vehicle” are inconclusive, the legislative history—including the commentary provided to the legislature during the 1971 revision of the Oregon Criminal Code—demonstrated that the legislature intended to include trailers within the scope of the statute. The court also noted that the verbs in the statute’s text suggest it was meant to cover a broad range of conduct and property, not just motor vehicles or self-propelled vehicles.The Supreme Court of the State of Oregon held that, for purposes of ORS 164.135, a “vehicle” includes trailers. It affirmed the decision of the Court of Appeals and remanded the case to the circuit court for further proceedings consistent with that decision. View "State v. McCarthy" on Justia Law

The defendant was charged with multiple offenses, including domestic violence aggravated assault, following an incident on May 12, 2021, in which she was alleged to have strangled her roommate and caused significant injuries. After being indicted on several charges, including attempted murder, the defendant reached an agreement to plead guilty to domestic violence aggravated assault, with the other charges dismissed and sentencing to be determined by the court. At the combined plea and sentencing hearing, the State described its evidence, including the victim’s account of repeated strangulation, and submitted an expert report on the victim’s injuries. The defendant, through counsel, acknowledged responsibility for the incident but limited her admission to the initial report of a single assault and did not contest additional details provided by the victim or the expert.The Cumberland County Unified Criminal Docket accepted the guilty plea and proceeded to sentencing. The State recommended a significant term of incarceration based on multiple incidents of strangulation and serious injury, while the defendant argued for a suspended sentence, citing her personal progress, lack of criminal history, and the risks of incarceration as a transgender individual. The court followed the statutory three-step sentencing process, considered both aggravating and mitigating factors, and imposed a seven-year sentence with all but four years suspended and three years of probation. The defendant appealed, arguing that her due process rights were violated when the sentencing court relied on unsworn victim statements and an expert report without cross-examination.The Supreme Judicial Court of Maine reviewed the case, applying de novo review to constitutional claims but only for obvious error due to the lack of contemporaneous objection. The Court held that due process does not require cross-examination or sworn testimony at sentencing so long as the information considered is reliable and the defendant has an opportunity to contest it. The Court found no obvious error and affirmed the judgment. View "State of Maine v. Miller" on Justia Law

Iowa enacted a statute, Iowa Code § 727.8A, which imposes heightened criminal penalties for using cameras or electronic devices to record or transmit images or data while trespassing on private property. Five animal-welfare organizations challenged this law, alleging it violates their members’ First Amendment rights by chilling their ability to record protests and activities, especially in spaces generally open to the public where they may be asked to leave but not specifically told to stop recording.Previously, the United States District Court for the Southern District of Iowa found the statute facially unconstitutional and permanently enjoined its enforcement. However, the United States Court of Appeals for the Eighth Circuit reversed that decision, noting that the statute could be constitutionally applied in some circumstances and remanded the case for further proceedings. On remand, two groups, including Iowa Citizens for Community Improvement (ICCI), pursued as-applied challenges, contending that the law chills their speech when it is used to prevent them from recording after being asked to leave premises otherwise open to the public. The district court dismissed these as-applied challenges, finding that the statute could be applied to their conduct without violating the First Amendment.On appeal, the United States Court of Appeals for the Eighth Circuit considered whether ICCI had standing, whether the case was ripe, and whether applying the statute in these circumstances violated the First Amendment. The court found that ICCI had standing and the case was ripe. It held that applying § 727.8A to prohibit recording while trespassing—even in spaces otherwise open to the public—does not violate the First Amendment because the statute is a content-neutral, narrowly tailored time, place, and manner restriction serving Iowa’s substantial interests in protecting property and privacy rights. The court affirmed the district court’s dismissal of ICCI’s as-applied challenge. View "Iowa Citizens for Community Improvement v. Reynolds" on Justia Law