Justia Criminal Law Opinion Summaries

After a physical altercation in a gas station parking lot, the defendant was charged with willful injury causing serious injury. The incident began when the defendant, after an argument with his girlfriend, was being driven home by her mother and her mother’s fiancé. An argument in the car led to a confrontation in the parking lot, during which the defendant punched, kicked, and threatened the fiancé, resulting in significant injuries including lost teeth and facial fractures. The police responded, and one officer viewed the store’s surveillance video on a monitor, recording it with his body camera. Due to errors by law enforcement and the store, the original surveillance video was not preserved, leaving only the bodycam recording as evidence.The Iowa District Court for Polk County admitted the bodycam recording into evidence over the defendant’s objections regarding authentication and the best evidence rule. The defendant was convicted by a jury and sentenced to prison. On appeal, the Iowa Court of Appeals reversed the conviction, finding that the bodycam recording was improperly admitted because it was not properly authenticated by the officer or other witnesses, and remanded for a new trial.The Iowa Supreme Court granted further review. It held that while the officer’s testimony alone was insufficient to authenticate the recording, subsequent testimony from the victim properly authenticated the video up to the point of the second hit to the ground. The court also found that the district court did not abuse its discretion in admitting the video under the best evidence rule, as the content was not seriously disputed and the absence of the original was adequately explained. The court concluded that there was sufficient evidence to support the conviction. The Iowa Supreme Court vacated the court of appeals’ decision and affirmed the district court’s judgment and sentence. View "State of Iowa v. Manning" on Justia Law

The case concerns a father whose two young children were found dead in his Nebraska home during his court-ordered visitation week. The children’s mother, living in Illinois, became alarmed after missing scheduled video calls and being unable to reach the father. Welfare checks by police initially did not result in entry to the home, but friends of the mother later entered and discovered the children deceased in their beds. The father was located and arrested in California, where he had interactions with two Catholic priests and made statements to law enforcement. The autopsies determined the children died from asphyxia due to smothering.The District Court for Sarpy County conducted a jury trial, during which the father was convicted of two counts of first degree murder and sentenced to consecutive life terms. The defense raised multiple pretrial and trial objections, including challenges to the admission of 911 calls, body camera footage, and statements to priests and police, as well as concerns about juror impartiality, media coverage, and the defendant’s competency following a medical incident during trial. The court overruled these objections and denied motions for mistrial and new trial. The defense also objected to the sentencing process, and the State argued that the trial court erred by granting credit for time served against the life sentences.The Nebraska Supreme Court reviewed the case and affirmed the convictions and consecutive life sentences, but modified the sentence to remove credit for time served, holding that such credit is not permitted against a life sentence. The court found no abuse of discretion or reversible error in the admission of evidence, handling of juror and media issues, or in the court’s rulings on competency and mistrial motions. The court also held that the defendant’s statements to law enforcement were voluntary and not obtained in violation of Miranda rights, and that any privilege regarding statements to clergy was either waived or, if error, harmless. View "State v. Price" on Justia Law

A man was charged in 2002 with multiple sexual offenses involving three minor males. In 2003, he entered a plea agreement, pleading no contest to several counts of committing lewd acts on children aged 14 or 15 and one count of oral copulation with a victim under 16, which was amended from a charge of forcible oral copulation to a nonforcible offense. He did not admit to using force or violence in his plea, but the factual basis for the plea referenced police reports describing acts involving force. He was sentenced to state prison in accordance with the plea agreement.In 2005, two psychologists evaluated him for commitment as a Mentally Disordered Offender (MDO) under California Penal Code section 2962. A chief forensic psychiatrist certified that he met the criteria, including having committed a crime involving force or violence, based on documentary evidence such as probation and police reports. The Board of Parole Hearings affirmed the certification. He did not challenge the certification in superior court at that time. He remained in custody under annual recommitment petitions, and his only prior challenge was an unsuccessful appeal of a 2022 recommitment order.After that, he filed a habeas corpus petition in Fresno County Superior Court in 2023, arguing that his conviction did not qualify as an MDO offense and that reliance on hearsay in the probation report violated his constitutional rights. The superior court denied the petition, finding the probation report admissible and sufficient to establish use of force.The California Court of Appeal, Fifth Appellate District, reviewed the case. It held that a habeas corpus petition is a proper vehicle to challenge an initial MDO certification based on static factors, even years later. The court found that the evidence was sufficient under the law at the time of certification, and that subsequent changes in evidentiary standards were not retroactive. The court also found no ineffective assistance of counsel. The petition for writ of habeas corpus was denied. View "In re Grinder" on Justia Law

In December 2007, the defendant participated in a gang-related shooting in which he, along with two other gang members, drove into rival territory. The defendant, seated in the back of the car, rolled down his window, confronted a rival gang member, exited the vehicle, and fired multiple shots, injuring the victim but not fatally. After the incident, the driver, an uninvolved high school student, reported the shooting to authorities. The defendant later admitted to being the shooter.The Orange County District Attorney charged the defendant and his codefendants with attempted murder, street terrorism, and related enhancements. In 2011, the defendant pleaded guilty and received a negotiated 19-year sentence. One codefendant went to trial and was convicted by a jury of the same charges and enhancements. In 2022, the defendant filed a petition under Penal Code section 1172.6 to vacate his attempted murder conviction and be resentenced, arguing that changes in the law regarding accomplice liability applied to his case. At the evidentiary hearing, the Superior Court of Orange County admitted transcripts from the codefendant’s trial over the defendant’s objection and denied the petition, finding the defendant was the actual shooter and thus ineligible for relief.On appeal, the defendant argued that the trial court erred by admitting evidence from a trial in which he was not a party. The California Court of Appeal, Fourth Appellate District, Division Three, held that Penal Code section 1172.6(d)(3) allows the admission of evidence from any prior hearing or trial, so long as it is admissible under current law, regardless of whether the petitioner was a party to that proceeding. The court affirmed the trial court’s order denying the petition. View "P. v. Ramos" on Justia Law

A registered nurse was convicted by a jury of misdemeanor elder or dependent adult abuse for her role in the care of a 62-year-old dependent adult, Michael H., at an unlicensed boarding house in Riverside, California. The facility, Secure Hands, was not authorized to provide medical care and was intended for residents who could manage their own daily activities. However, Michael, who had recently suffered a stroke and had significant physical and mental limitations, was admitted to the facility under the nurse’s assessment and supervision. The nurse determined his care needs, recommended equipment, and was responsible for ensuring that appropriate caregivers were available. Despite knowing the facility was not equipped for dependent adults, she admitted Michael and did not report or address ongoing concerns about his care, including poor hygiene and lack of basic necessities, which were repeatedly brought to her attention.The Superior Court of Riverside County initially charged the nurse with four counts of felony elder or dependent adult abuse, but one count was dismissed before trial. The jury deadlocked on two counts, resulting in a mistrial for those, but found her guilty of the lesser included misdemeanor offense regarding Michael. She was sentenced to four months in county jail and fined $1,000.On appeal, the nurse argued that the definition of “care or custody” from the Elder Abuse and Dependent Adult Civil Protection Act should apply to her criminal prosecution, and that there was insufficient evidence she had such responsibility. The California Court of Appeal, Fourth Appellate District, Division Two, rejected this argument, holding that “care or custody” in Penal Code section 368(c) should be interpreted according to its plain and ordinary meaning, not the more restrictive civil definition. The court found substantial evidence supported the jury’s verdict and affirmed the conviction. View "P. v Molina" on Justia Law

Muhammad Arif, the owner of convenience stores in Arkansas, was accused of soliciting a fifteen-year-old girl, the daughter of his handyman, to engage in sexual acts in exchange for money on two occasions in 2019. Both incidents occurred while Arif was driving the girl home in his vehicle. The girl declined his advances, recorded the conversations, and later reported the incidents to her parents and the police. Arif was initially prosecuted under Arkansas state law, but the federal government took over, charging him under 18 U.S.C. § 1591(a)(1), which criminalizes commercial sex trafficking of a minor “in or affecting interstate or foreign commerce.”The United States District Court for the Eastern District of Arkansas presided over the trial. After the jury found Arif guilty, he moved for a judgment of acquittal, arguing that the government failed to prove the required element that his conduct affected interstate commerce. The district court agreed, granting the motion and concluding that merely driving a car manufactured out of state and giving money to the victim did not constitute an actual effect on interstate commerce as required by precedent.The United States Court of Appeals for the Eighth Circuit reviewed the district court’s decision de novo, considering whether the evidence was sufficient to establish the interstate commerce element of the federal statute. The appellate court held that the government’s evidence—Arif’s use of a car manufactured in another state, the transfer of $20, and the use of local roadways—was insufficient to show an actual effect on interstate commerce. The court distinguished this case from others where use of the internet, interstate travel, or communications had a clear impact on commerce. The Eighth Circuit affirmed the district court’s judgment of acquittal. View "United States v. Arif" on Justia Law

Matthew Smith was charged with first degree murder following a shooting outside the Press Box bar in August 2012. Multiple eyewitnesses identified Smith as the shooter, both in police lineups and at trial. The lineups included fillers who differed from Smith in age and hairstyle, and in the second lineup, Smith wore a distinctive red and white shirt that witnesses had described the shooter as wearing. Physical evidence included shell casings and a revolver found in a vehicle from which Smith fled, as well as a photograph of Smith in the bar wearing the same shirt. Smith’s mother was excluded from the courtroom during parts of the trial because she was listed as a potential witness.The Cook County Circuit Court denied Smith’s motions to suppress the lineup identifications and to exclude the photograph, and after a jury trial, Smith was convicted and sentenced to 30 years in prison. On appeal, the Illinois Appellate Court reversed the conviction and remanded for a new trial, finding that excluding Smith’s mother violated his right to a public trial. The appellate court also found errors regarding the suggestiveness of the second lineup, a discovery violation in the gunshot residue expert’s testimony, improper closing arguments by the prosecution, and error in sending the photograph to the jury.The Supreme Court of Illinois reviewed the case and held that excluding Smith’s mother did not violate his right to a public trial, as the courtroom remained open to other family members, spectators, and the media. The court further found that the second lineup was not unduly suggestive, the discovery violation regarding the gunshot residue expert did not warrant reversal, the trial court did not abuse its discretion in allowing the jury to view the photograph, and the challenged prosecutorial comments did not constitute reversible error. The Supreme Court reversed the appellate court’s judgment, affirmed the conviction, and remanded for consideration of any remaining unresolved issues. View "People v. Smith" on Justia Law

The case concerns William Coston, who was accused of sexually abusing a minor over several years, beginning when the victim was four years old. The abuse included multiple acts of rape, the introduction of controlled substances, and sexually grooming the child. Initially, Coston was charged with three counts of rape, but the State later amended the charges to include a total of ten counts of rape, one count of introduction of a controlled substance into the body of another person, and one count of sexually grooming a child. The evidence supporting these charges had been available to the defense throughout the discovery process.The Garland County Circuit Court presided over Coston’s jury trial in March 2024. Prior to trial, the State amended the criminal information to add the additional charges. Coston objected to the timing and number of the new charges, arguing that the amendment was arbitrary and created confusion, but he acknowledged that the evidence supporting the charges had been disclosed from the outset. He did not move to strike the amendment or request a continuance. The circuit court overruled his objection, noting that amendments to the information are permitted up to the point the case is submitted to the jury. After trial, Coston was convicted on all counts and sentenced to consecutive terms of imprisonment.On appeal to the Supreme Court of Arkansas, Coston argued that the circuit court abused its discretion by allowing the State to amend the information shortly before trial. The Supreme Court of Arkansas held that the amendment did not change the nature or degree of the offenses, as it merely added counts of the same offense, and that Coston was not unfairly surprised or prejudiced by the amendment. The court affirmed the circuit court’s decision, finding no prejudicial error. View "COSTON v. STATE OF ARKANSAS" on Justia Law

After a minor car accident outside a Safeway parking lot, Brittany Shantel Carrington and her three passengers, including her teenage daughter, became involved in a physical altercation with Brooklyn Brown and Marylynn Jones, the occupants of the other vehicle. The situation escalated from an exchange of insurance information to a brawl. During the fight, Carrington retrieved an umbrella from her car and, according to testimony, used it to strike the windshield of Brown’s vehicle and hit Jones, who sustained injuries. Police arrived and arrested Carrington, recovering the umbrella from her car.The Superior Court of the District of Columbia presided over a bench trial. The trial judge found the facts surrounding the altercation unclear but ultimately credited Brown’s identification of Carrington as the person who broke the windshield and struck Jones with the umbrella. The court found Carrington’s account not credible and determined that she acted out of anger rather than self-defense. Carrington was convicted of simple assault, destruction of property less than $1000, and attempted possession of a prohibited weapon (attempted PPW). She was sentenced to probation and fines, with the execution of the sentence suspended.On appeal, the District of Columbia Court of Appeals reviewed Carrington’s sufficiency of evidence claims de novo. The court affirmed the convictions for simple assault and destruction of property, finding sufficient evidence and no error in the trial court’s credibility determinations or rejection of self-defense. However, the appellate court reversed and vacated the conviction for attempted PPW, holding that the evidence did not establish the umbrella as a “dangerous weapon” under D.C. law in this instance, as there was insufficient proof that it was likely to produce death or great bodily injury in the manner used. View "Carrington v. United States" on Justia Law

A criminal defendant was charged with murder and released on a $1 million bail bond posted by United States Fire Insurance Company. After his release, the defendant appeared at several hearings, sometimes personally and sometimes through his attorney under a Penal Code section 977 waiver, which allows a defendant to be represented by counsel at certain proceedings. On March 15, 2022, the court ordered the defendant to return for all future hearing dates and continued the bond. On April 26, 2022, the defendant’s attorney appeared on his behalf, and the court ordered the defendant to be personally present at the next hearing. The defendant failed to appear on May 18, 2022, citing illness, and again on June 2, 2022, at which point the court vacated the trial date, forfeited the bond, and sent notice to the surety.United filed a motion in the Superior Court of Riverside County to vacate the forfeiture and exonerate the bond, arguing that the court should have forfeited the bond on April 26, 2022, when the defendant first failed to appear without sufficient excuse, and that the June 2 forfeiture was void for lack of jurisdiction. The trial court denied the motion. After summary judgment was entered against United, it filed a motion to set aside the judgment, again arguing lack of jurisdiction. The trial court denied this motion, finding the issue barred by res judicata.The California Court of Appeal, Fourth Appellate District, Division One, reviewed the denial of the motion to set aside summary judgment. The court held that the trial court was not divested of jurisdiction to forfeit the bail bond on June 2, 2022, because the defendant was not required to personally appear on April 26, 2022, and his appearance through counsel was valid under section 977. The order denying the motion to set aside summary judgment was affirmed. View "People v. United States Fire Insurance Co." on Justia Law