Justia Criminal Law Opinion Summaries

Michael Connor was convicted in 2013 after a bench trial in Livingston County, Illinois, of five counts of predatory criminal sexual assault of a child. The offenses involved his daughter and stepdaughter, occurring when they were between five and seven years old. The statutory penalty was six to sixty years per count, to be served consecutively, but if convicted of assaulting multiple victims, the law required a mandatory life sentence. After his conviction, Connor received the mandatory life term.After his direct appeal was unsuccessful, Connor pursued postconviction relief in Illinois state court, arguing that his trial counsel was constitutionally ineffective during plea negotiations by failing to inform him that he faced a mandatory life sentence. He claimed this omission led him to reject an 18-year plea offer. At an evidentiary hearing, Connor testified that he would have accepted the plea had he known about the life sentence. The trial judge, however, found this testimony not credible, noting that Connor had repeatedly asserted his innocence and had unequivocally stated at sentencing that he would not have pleaded guilty even if aware of the outcome. The trial court denied postconviction relief, and the Illinois Appellate Court affirmed, finding no reasonable probability that Connor would have accepted the plea but for counsel’s alleged errors.Connor then sought federal habeas relief in the United States District Court for the Central District of Illinois, which was denied. On appeal, the United States Court of Appeals for the Seventh Circuit reviewed the denial. The Seventh Circuit held that federal habeas relief was not warranted because Connor failed to rebut, by clear and convincing evidence, the state court's credibility finding that he would not have accepted the plea. The judgment of the district court was affirmed. View "Connor v. Greene" on Justia Law

In this case, the petitioner was convicted and sentenced to death for the murder and robbery of two men in a Kentucky convenience store in 1987. After being identified as a suspect, he confessed to the crimes but later asserted an insanity defense at trial. His mental health was evaluated by state experts, who found him competent and not suffering from a mental illness that would have excused his conduct. At trial, the defense presented testimony from the petitioner and a psychologist, but the jury found him guilty on all counts and recommended the death penalty. The penalty phase included limited mitigation evidence and testimony.Following his conviction and sentencing, the petitioner pursued direct appeals and post-conviction relief in Kentucky state courts, including before the Kentucky Supreme Court, and sought certiorari from the United States Supreme Court, which was denied multiple times. He then filed a federal habeas corpus petition in the United States District Court for the Eastern District of Kentucky, asserting several constitutional claims, including ineffective assistance of counsel, improper jury instructions on the insanity defense, and cumulative error. The district court denied relief, but granted certificates of appealability on several issues.On appeal, the United States Court of Appeals for the Sixth Circuit first held that the Antiterrorism and Effective Death Penalty Act (AEDPA) is constitutional, rejecting the argument that it unconstitutionally restricts federal habeas review. Applying AEDPA deference, the court found that the Kentucky Supreme Court’s decisions regarding the jury instructions and most of the ineffective assistance of counsel claims were neither contrary to nor unreasonable applications of clearly established federal law. Claims not subject to AEDPA deference failed under de novo review because the petitioner could not show prejudice. The cumulative error claim was found to be procedurally defaulted. Accordingly, the Sixth Circuit affirmed the denial of the habeas petition in full. View "Sanders v. Plappert" on Justia Law

Federal and local law enforcement investigated an individual as part of a drug trafficking organization operating in Tennessee. Over ten months, agents used various investigative techniques, including wiretaps, confidential informants, controlled narcotics buys, and electronic surveillance. Based on the evidence, a grand jury indicted the defendant on multiple counts, including conspiracy to distribute cocaine and heroin, drug distribution, money laundering, and related offenses. The defendant was arrested at his home, questioned by agents, and, after receiving Miranda warnings, confessed to involvement in drug trafficking. Agents also seized and searched his cellphones with his verbal and written consent.Before trial in the United States District Court for the Middle District of Tennessee, the defendant filed motions to suppress his post-arrest statements and evidence from the cellphone searches, arguing violations of his Fifth, Sixth, and Fourth Amendment rights. The district court denied these motions after evidentiary hearings. At trial, a jury convicted the defendant on all counts, and the district court imposed a prison sentence and supervised release.On appeal, the United States Court of Appeals for the Sixth Circuit reviewed the denial of the suppression motions. The appellate court held that the defendant’s post-Miranda confession was not coerced, the warnings given reasonably conveyed his rights, and even if there were deficiencies, any error was harmless due to overwhelming other evidence of guilt. The court further found that the defendant voluntarily consented to the cellphone searches, and there was no Fourth Amendment violation. The court noted that no evidence from the cellphones was introduced at trial. Accordingly, the Sixth Circuit affirmed the district court’s denial of the suppression motions and upheld the convictions. View "United States v. Magallon Guerrero" on Justia Law

A physician was charged with unlawfully distributing oxycodone, a controlled substance, after prescribing it to a patient he knew was addicted to opioids, and who subsequently died of a drug overdose. The government alleged that the prescriptions were not issued for legitimate medical purposes and were outside the usual course of professional practice. The physician pled guilty to all charges in 2019. At his plea hearing, the district court explained that the government would have to prove the prescriptions were unauthorized but, following then-binding Fourth Circuit precedent, did not tell him the government also had to prove he knew his conduct was unauthorized.Nearly three years later, the Supreme Court decided Ruan v. United States, holding that, under 21 U.S.C. § 841, the government must prove that a physician “knowingly or intentionally” acted in an unauthorized manner when prescribing controlled substances. The physician filed a motion under 28 U.S.C. § 2255 to vacate his convictions, arguing his guilty plea was invalid because he had not been informed of the scienter requirement articulated in Ruan. The United States District Court for the Middle District of North Carolina denied the motion, finding the claim procedurally defaulted because it was not raised earlier and that Ruan was not so novel as to excuse the default, since similar arguments were available and made by others at the time of the plea.The United States Court of Appeals for the Fourth Circuit affirmed. The court held that the legal basis for the physician’s Ruan-style mens rea claim was reasonably available at the time of his guilty plea, given existing Supreme Court precedent such as Rehaif v. United States. Therefore, the claim was not sufficiently novel to provide cause to overcome procedural default, and collateral relief was precluded. View "United States v. Dimkpa" on Justia Law

Two individuals were separately stopped and searched by law enforcement officers in Maryland in January 2023, prior to the effective date of a new statute, Criminal Procedure Article (“CP”) § 1-211. The stops and searches were based solely on the odor of cannabis. Contraband was discovered in both cases, and the individuals were charged with various offenses. Each moved to suppress the evidence, arguing that the newly enacted statute, effective July 1, 2023, rendered evidence obtained solely on the basis of cannabis odor inadmissible, even though their searches had occurred before the law took effect.In both cases, the Circuit Court for St. Mary’s County and the Circuit Court for Worcester County denied the motions to suppress, ruling that the statute did not apply retroactively because it was not in effect at the time of the searches. The Appellate Court of Maryland affirmed both decisions, reasoning that the statute created a new substantive right and remedy that only attached to searches occurring on or after its effective date. The Appellate Court relied on its prior decision in Kelly v. State and distinguished these cases from others involving procedural or remedial statutes.Upon review, the Supreme Court of Maryland affirmed the judgments of the Appellate Court. The Court held that CP § 1-211’s exclusionary remedy applies only to evidence discovered or obtained in violation of the statute, and no violation can occur before the statute’s effective date. The Court found the statute unambiguous, rejected arguments for retroactive application based on procedural or remedial theories, and emphasized the General Assembly’s clear intent for prospective application. Therefore, the exclusionary remedy in CP § 1-211(c) does not apply to pre-enactment cannabis-related stops or searches, and the evidence was properly admitted. View "Cutchember v. State" on Justia Law

The case involved a traffic stop in Salem, New Hampshire, where a police officer, upon detecting a strong odor of alcohol in a vehicle, interacted with its passengers. The defendant, seated in the back, became verbally aggressive toward the officer, yelling and cursing. After being ordered out of the vehicle, the defendant stepped toward the officer, pointed at him, and shoved his finger into the officer’s chest. When the officer attempted to arrest him, the defendant pulled away, struggled, and resisted being handcuffed. A portion of this encounter was captured on video by another passenger.Following these events, the defendant was charged in the Rockingham County Superior Court with misdemeanor counts of simple assault and resisting arrest. At trial, the jury was presented with video evidence and heard testimony from the officers involved. The defendant moved to dismiss the charges for insufficient evidence, but the trial court (St. Hilaire, J.) denied these motions. The jury found the defendant guilty on both counts, leading to the present appeal.The Supreme Court of New Hampshire reviewed the case. The defendant argued that appellate review of video evidence should be de novo, asserting that the court was in as good a position as the jury to interpret such evidence. The court rejected this argument, holding that video evidence must be reviewed under the traditional standard: all evidence, including video and live testimony, is viewed in the light most favorable to the State to determine whether any rational jury could find guilt beyond a reasonable doubt. Applying this standard, the court found sufficient evidence to support both convictions. The court also rejected the defendant’s argument that his conduct was de minimis, noting it was not preserved or plain error. The court affirmed the convictions. View "State v. Wells" on Justia Law

A former ship captain was prosecuted after a fire broke out on his vessel, resulting in the deaths of thirty-four passengers and crew members. The ship, used for recreational diving, had multiple fire safety features and regulatory requirements, including the need for a roving night patrol and crew training in fire response. The captain had extensive maritime experience, but his crew was relatively inexperienced and had not been adequately trained in emergency procedures. On the night of the incident, no one was assigned to patrol for fires, and when the fire was discovered, the crew was unprepared to respond effectively. The captain contacted the Coast Guard but did not use the ship’s public address system to warn those below deck or attempt a rescue, ultimately abandoning ship along with other crew members. All individuals below deck died from smoke inhalation and asphyxiation.The United States District Court for the Central District of California presided over the initial criminal case. The first indictment tracked the language of the seaman’s manslaughter statute but was dismissed by the district court for not alleging gross negligence, which the court believed was required based on prior interpretations of a different manslaughter statute. The government reindicted, alleging gross negligence, and the case proceeded to trial. The jury was instructed that conviction could follow if the captain engaged in “misconduct and/or acted with gross negligence.” The jury found the captain guilty.On appeal, the United States Court of Appeals for the Ninth Circuit held that the seaman’s manslaughter statute, 18 U.S.C. § 1115, requires only ordinary negligence, not gross negligence. The court further concluded that, even if the jury instruction’s use of “misconduct” was erroneous, any such error was harmless because the instructions repeatedly referenced the higher gross negligence standard, the prosecution did not argue for a lower standard, and overwhelming evidence supported the conviction. The judgment was affirmed. View "USA V. BOYLAN" on Justia Law

Law enforcement in central Arkansas identified an individual as a source of methamphetamine distribution and arranged a controlled buy using a confidential informant. On March 28, 2022, the informant, equipped with recording devices, purchased over 100 grams of methamphetamine from the individual, who was subsequently arrested. The video and transcript of the transaction captured the exchange, including a discussion about a firearm in the vehicle. Laboratory tests later confirmed the substance’s identity and quantity.The United States District Court for the Eastern District of Arkansas presided over the trial. The defendant objected to the admission of the video, transcript, and related evidence on grounds of inadequate authentication, hearsay, and unfair prejudice due to the firearm discussion. The district court overruled these objections, admitted the evidence, and provided a limiting instruction regarding the transcript. After the jury convicted the defendant of distributing 50 or more grams of methamphetamine, the court sentenced him to 125 months’ imprisonment. The defendant argued at sentencing that he was subject to sentencing entrapment and requested a sentence below the statutory minimum, but the district court denied these requests.On appeal, the United States Court of Appeals for the Eighth Circuit reviewed the district court’s evidentiary rulings for abuse of discretion and the sentencing issues for clear error and plain error. The appellate court held that the video and transcript were properly authenticated, their probative value was not substantially outweighed by unfair prejudice, and the statements in the recording were either admissible as party-opponent admissions or provided contextual background rather than hearsay. The court also found no clear error in the rejection of the sentencing entrapment argument and concluded that the district court adequately explained its sentencing decision. The Eighth Circuit affirmed the judgment of the district court. View "United States v. Walker" on Justia Law

The case concerns Brad Wendt, who owned two firearms stores in Iowa and also served as the Chief of Police for the small city of Adair. As police chief, Wendt had the authority to write official letters (“law letters”) that allowed his stores to acquire machine guns for the Adair Police Department or for demonstration purposes. Over several years, Wendt wrote numerous law letters to acquire ninety machine guns, some of which he resold for significant profit. Evidence showed that these acquisitions and demonstrations were not genuinely for police department use or potential future purchase but were instead for personal gain and to facilitate sales to other firearms dealers. Wendt also arranged for machine guns to be acquired and demonstrated by other dealers without legitimate department interest.After a jury trial in the United States District Court for the Southern District of Iowa, Wendt was convicted on multiple counts, including making false statements, conspiracy to make false statements and defraud the Bureau of Alcohol, Tobacco, Firearms and Explosives (ATF), and illegal possession of a machine gun. The district court sentenced him to sixty months in prison, imposed a fine, and ordered the forfeiture of firearms. Wendt moved for acquittal or a new trial, but the district court denied these motions.On appeal to the United States Court of Appeals for the Eighth Circuit, Wendt challenged his convictions and sentence. The Eighth Circuit affirmed the convictions and sentence related to false statements and conspiracy, finding that the jury instructions fairly reflected the law and that there was no ambiguity requiring special instruction. However, the court found that the statute criminalizing possession of a machine gun was unconstitutionally vague as applied to Wendt in his role as police chief. The court reversed his conviction for illegal possession of a machine gun, remanded for vacatur of that conviction, but affirmed the remaining convictions and sentence. View "United States v. Wendt" on Justia Law

After unlawfully entering his ex-wife’s home in violation of a court-issued protection order, the defendant was charged with second degree burglary and additional offenses. The protection order, issued under Colorado law, specifically prohibited the defendant from contacting his ex-wife or entering her residence. During the incident, the defendant jumped a fence, damaged property, and entered the home despite his ex-wife’s objections, prompting her to lock herself in the bathroom and call the police. Officers arrived to find the defendant leaving the property, and he was subsequently taken into custody.The Weld County District Court held a preliminary hearing on the burglary charge. The prosecution presented evidence of the defendant’s violation of the protection order. The defendant did not dispute the factual allegations but argued that his conduct did not amount to a “crime against another person or property” under the second degree burglary statute. The District Court, relying on the Supreme Court of Colorado’s decision in People v. Rhorer, concluded that violating a protection order is a predicate crime for second degree burglary because it constitutes a crime against a person or property. The court found probable cause and set the charge for trial.The Supreme Court of Colorado exercised its original jurisdiction to review the District Court’s ruling. The court affirmed the trial court’s interpretation of the law, holding that a criminal violation of a protection order under section 18-6-803.5, C.R.S., categorically qualifies as a “crime against another person or property” for purposes of the second degree burglary statute. Therefore, such a violation may properly serve as the predicate offense for second degree burglary. The Supreme Court discharged the order to show cause and remanded the case for further proceedings. View "People v. Dilka" on Justia Law