Justia Criminal Law Opinion Summaries

Jeremiah Banks, a state prisoner, filed a habeas corpus petition under 28 U.S.C. § 2254 in January 2021, alleging nine claims. Two of these claims were exhausted, while the remaining seven were unexhausted. Banks also moved for a stay and abeyance under Rhines v. Weber to return to state court and exhaust the unexhausted claims. However, after filing his federal petition, Banks took no action to exhaust his seven unexhausted claims for over a year.The United States District Court for the Central District of California denied Banks’s motion for a Rhines stay in April 2022, citing his failure to show good cause for his post-filing lack of diligence and intentional delay in reviewing his federal petition. The district court dismissed Banks’s two exhausted claims with prejudice and his seven unexhausted claims without prejudice.The United States Court of Appeals for the Ninth Circuit reviewed the case and held that a district court does not abuse its discretion by considering a petitioner’s diligence in pursuing state court remedies after filing a federal petition when evaluating good cause under Rhines. The court emphasized that the district court must consider a petitioner’s post-filing diligence in pursuing state court remedies. The Ninth Circuit found that Banks failed to demonstrate good cause excusing his lack of diligence and that the district court did not abuse its discretion in denying the Rhines stay and abeyance.Additionally, the Ninth Circuit rejected Banks’s argument that the district court contravened Rose v. Lundy by not offering him the choice of withdrawing his entire mixed habeas petition. The court explained that Banks did not have such a choice because the district court dismissed his two exhausted claims with prejudice. The Ninth Circuit affirmed the district court’s denial of the Rhines stay and dismissal of Banks’s habeas petition. View "Banks v. Allison" on Justia Law

In 2018, Detective James Gaddy of the St. Charles County, Missouri Police Department investigated a large-scale drug distributor, Guy Goolsby, and obtained wiretap authorization for Goolsby’s cell phone. The wiretap revealed that Freeman Whitfield IV was involved in the drug distribution. In 2019, Goolsby directed Whitfield to retrieve drugs, and Whitfield was later implicated in the murder of Antonio Boyd, a cooperating witness. Investigators linked Whitfield to the crime scene through cell tower data and intercepted conversations. In 2021, search warrants for Whitfield’s residences led to the discovery of firearms, ammunition, drugs, and drug proceeds.The United States District Court for the Eastern District of Missouri denied Whitfield’s pretrial motions to suppress evidence and to sever counts related to the murder from the drug charges. The court found probable cause for the search warrants and ruled that the wiretap evidence was obtained lawfully. The court also determined that the charges were sufficiently related to be tried together. Whitfield was found guilty on all counts and sentenced to life imprisonment.The United States Court of Appeals for the Eighth Circuit reviewed the case. The court upheld the district court’s denial of Whitfield’s motions to suppress, finding that the affidavits supporting the search warrants established probable cause and that the wiretap evidence met the necessity requirement under 18 U.S.C. § 2518. The court also affirmed the denial of the motion to sever, concluding that the charges were properly joined and that Whitfield failed to demonstrate any resulting prejudice. The Eighth Circuit affirmed the district court’s judgment. View "United States v. Whitfield" on Justia Law

Daniel Lockridge, a decorated combat Marine, was involved in methamphetamine trafficking after returning to the U.S. in 2009. He initially used methamphetamine to manage his PTSD and later began selling it, eventually becoming a significant supplier in Chattanooga, Tennessee. Lockridge pleaded guilty to aiding and abetting possession with intent to distribute methamphetamine and was sentenced to 210 months in prison followed by three years of supervised release. His supervised release conditions included mandatory mental-health and substance-abuse treatment, as directed by a probation officer.The United States District Court for the Eastern District of Tennessee imposed these conditions, and Lockridge objected, arguing that the court must preauthorize any inpatient treatment and set a frequency for drug testing, rather than delegating these decisions to a probation officer. The district court overruled his objections, leading to Lockridge's appeal.The United States Court of Appeals for the Sixth Circuit reviewed the case. The court held that the district court did not relinquish its authority by not specifying the details of the treatment programs at sentencing. Instead, it retained the discretion to make these decisions closer to the time of Lockridge's supervised release, allowing the probation officer to assess his needs and recommend appropriate treatment. The court emphasized that the ultimate authority to modify or enforce the conditions of supervised release remains with the district court, ensuring compliance with Article III of the U.S. Constitution.The Sixth Circuit affirmed the district court's decision, concluding that the delegation of certain responsibilities to the probation officer did not violate constitutional principles, as the district court retained the final decision-making authority. View "United States v. Lockridge" on Justia Law

In 2020, a police officer applied for a criminal complaint in the District Court, alleging that the defendant possessed a loaded firearm while intoxicated. A clerk-magistrate denied the application, finding no probable cause that the defendant had a firearm under his control inside a motor vehicle. No review of this decision was sought. Over two years later, the same officer filed a new application for the same offense with the same facts, and a different clerk-magistrate found probable cause and issued the complaint.The defendant filed a petition for extraordinary relief, arguing that the issuance of the complaint was barred by collateral estoppel and that the delay violated his due process rights. A single justice of the county court reserved and reported the petition to the full court.The Supreme Judicial Court of Massachusetts held that the principles of collateral estoppel did not bar the issuance of the complaint because the initial denial was not a final judgment. The court noted that a District Court determination of no probable cause is not conclusive and does not bar a subsequent indictment for the same offense. The court also found no due process violation, as the defendant did not have a constitutionally protected interest in the finality of a show cause determination, and the delay did not cause severe prejudice to the defendant's ability to mount a defense. The court remanded the case to the county court for entry of a judgment denying the defendant's petition for extraordinary relief. View "Cabrera v. Commonwealth" on Justia Law

In the early morning of July 18, 2022, Deputy Anthony Jenson of the Lincoln County Sheriff’s Office observed a yellow Volkswagen GTI with Oregon plates at a gas station. The vehicle had been under surveillance since a Border Patrol stop on July 5, 2022. The Volkswagen exhibited suspicious behavior, such as abruptly pulling into another gas station without refueling and making a series of unusual turns. Detective Brandon Holzer, who was also monitoring the vehicle, eventually found it parked in the brush off a dirt road. Upon approaching the vehicle, Holzer detected the smell of burnt methamphetamine and other substances, leading to a search that uncovered drugs and paraphernalia.The Nineteenth Judicial District Court, Lincoln County, denied Herzog’s motion to suppress the evidence, concluding that Detective Holzer had a particularized suspicion to stop the vehicle. Herzog subsequently entered a plea agreement, pleading guilty to Criminal Possession of Dangerous Drugs while preserving her right to appeal the suppression ruling.The Supreme Court of the State of Montana reviewed the case, focusing on whether the District Court relied on clearly erroneous findings of fact in denying the motion to suppress. The court affirmed the lower court’s decision, finding that the District Court’s factual findings were supported by substantial credible evidence. The court held that the totality of the circumstances, including the vehicle’s evasive maneuvers and irregular parking, provided Detective Holzer with sufficient particularized suspicion to conduct a Terry stop. Thus, the evidence obtained from the search was admissible. View "State v. H. Herzog" on Justia Law

Christopher Lapointe was arrested on July 24, 2020, for driving under the influence (DUI) in Montana, with a blood alcohol content of .203. The State found that Lapointe had six prior DUI convictions in California and charged him with Felony DUI (fourth or subsequent offense) under Montana law. Lapointe moved to dismiss the felony charge, arguing that California's DUI statute was not sufficiently similar to Montana's DUI statute, and thus his prior California convictions should not count as prior convictions for felony enhancement purposes.The Eighteenth Judicial District Court of Gallatin County denied Lapointe's motion to dismiss on March 6, 2023, finding that his California convictions could be used for sentence enhancement. Lapointe pled guilty to Felony DUI but reserved the right to appeal the ruling on his motion. On April 24, 2023, the District Court sentenced him to 49 months with the Department of Corrections, with three years suspended.The Supreme Court of the State of Montana reviewed the case and held that California's DUI statute is sufficiently similar to Montana's DUI statutes to support a felony DUI charge. The court noted that both statutes define intoxication similarly and that the place of offense element in California's statute, which includes both public and private property, is sufficiently similar to Montana's requirement that the offense occurs on public ways. The court affirmed the District Court's order denying Lapointe's motion to dismiss the felony enhancement. View "State v. C. Lapointe" on Justia Law

Gary Matthews and Monte Brannan collaborated on a project to redevelop a landmark hotel in Peoria, Illinois. Instead of fulfilling their financial obligations to lenders, they diverted project revenue for personal gain. This led to federal charges of mail fraud and money laundering, resulting in guilty verdicts by a jury.The United States District Court for the Central District of Illinois oversaw the initial trial. Matthews and Brannan were convicted of mail fraud, money laundering, and, in Brannan’s case, conspiracy to commit money laundering. They appealed their convictions, raising multiple issues.The United States Court of Appeals for the Seventh Circuit reviewed the case. The court found the evidence against Matthews and Brannan overwhelming, affirming their convictions. The court noted that Matthews and Brannan failed to comply with Circuit Rule 30(b)(1) by not including necessary district court rulings in their appendices, which hindered the appellate review process. Despite this, the court ensured a fair review by independently locating the relevant rulings. The court ordered Matthews’s and Brannan’s counsel to show cause why they should not be sanctioned for their violations of Circuit Rule 30. The court affirmed the district court’s judgment, ensuring that Matthews and Brannan received fair consideration of their appeals. View "USA v Brannan" on Justia Law

Nicole Lee Hunt was observed by Detective Nicholas Monaco of the Ravalli County Sheriff’s Office driving a vehicle without license plates. Monaco had prior intelligence linking Hunt and her residence, Apartment 1, to drug activity, specifically methamphetamine trafficking. During the traffic stop, Hunt exhibited signs of nervousness, had glassy red eyes, and made inconsistent statements about her activities. Monaco expanded the stop into a drug investigation, conducted a canine sniff, and found a package containing methamphetamine in Hunt’s vehicle.The Twenty-First Judicial District Court, Ravalli County, denied Hunt’s motion to suppress the evidence obtained from the search, finding that Monaco had particularized suspicion to expand the traffic stop into a drug investigation. During the trial, Hunt testified that she knew the package contained drugs but claimed it belonged to her dealer, Trent Parker, and denied any intent to distribute. The State called Katrina Conway as a rebuttal witness, who testified that Hunt had previously sold her methamphetamine. The District Court allowed this testimony, concluding that Hunt’s testimony opened the door to evidence of her prior bad acts. The jury found Hunt guilty of felony criminal possession of dangerous drugs with intent to distribute.The Supreme Court of the State of Montana reviewed the case and affirmed the District Court’s denial of Hunt’s suppression motion, agreeing that there was particularized suspicion to justify the expanded investigation. However, the Supreme Court found that the District Court erred in allowing Conway’s rebuttal testimony, as Hunt’s cross-examination responses did not open the door to such evidence. The Supreme Court reversed Hunt’s conviction and remanded the case for a new trial. View "State v. N. Hunt" on Justia Law

The defendant returned home after a period away and, while intoxicated, became upset upon discovering his brother’s marijuana plants in his basement. After confronting his brother, the defendant visited a neighbor’s house, where he found the neighbor’s daughter and another individual, Bill, using methamphetamine. Concerned that the neighbor, recently released from prison, could get into trouble, the defendant confronted those present. A verbal altercation escalated, resulting in the defendant punching Bill unconscious. Upon regaining consciousness, Bill struck the defendant with a hammer, leading to a physical struggle involving the defendant’s son and friend. The group retreated outside, but Bill followed, allegedly threatening to kill the defendant and his family. The defendant’s son retrieved a gun, which the defendant used to shoot and kill Bill after warning him to stop approaching.The Twentieth Judicial District Court, Sanders County, presided over the trial. The defense did not object to the jury instructions regarding self-defense and the use of force to prevent a forcible felony, and stipulated to the remaining instructions. The jury found the defendant guilty of deliberate homicide with a dangerous weapon. The defendant appealed, arguing that the District Court erred by not providing a specific defense of others instruction and that his counsel was ineffective for not requesting one.The Supreme Court of the State of Montana reviewed the case. It held that the District Court did not abuse its discretion in instructing the jury, as the instructions given adequately covered the law regarding self-defense and defense of others through the “forcible felony” instruction. The Court also found no ineffective assistance of counsel, as there was a plausible justification for counsel’s actions and no reasonable probability that a different instruction would have changed the outcome. The judgment was affirmed. View "State v. C. Rossbach" on Justia Law

In 1993, a man was convicted by a jury of multiple crimes, including torture, mayhem, corporal injury to a child, and child abuse, after he bound his then-girlfriend’s five-year-old daughter with tape and forced her into scalding water, causing severe burns and permanent injuries. The child, R.P., suffered extensive medical trauma, permanent disfigurement, and lifelong disabilities. At sentencing, the trial court imposed a restitution fine but did not order direct victim restitution. Decades later, after the defendant was granted parole, the prosecution sought restitution for R.P. and her parents to cover medical expenses and lost wages.The Superior Court of San Luis Obispo County held a restitution hearing in 2023, where R.P. and her parents testified about the economic impact of the injuries. The court found their testimony credible and awarded restitution for medical expenses and both past and future lost wages. The defendant objected, arguing that the court lacked jurisdiction to impose restitution so long after sentencing, that the delay violated his constitutional rights, and that the discount rate used to calculate present value of future wages was unsupported. He did not challenge the amounts claimed.The California Court of Appeal, Second Appellate District, Division Six, reviewed the case. The court held that there is no time limit restricting a court’s authority to order victim restitution in a criminal case, even decades after sentencing, when the original sentence omitted such an order. The court also found no violation of constitutional rights due to the delay, noting the defendant forfeited some arguments by not raising them earlier, and upheld the trial court’s use of the discount rate. The restitution order was affirmed. View "P. v. Sinay" on Justia Law