Justia Criminal Law Opinion Summaries

The appellant pleaded guilty in 2015 to driving under the influence and resisting arrest, receiving a sentence of incarceration followed by probation. While serving probation for this 2015 case, he was arrested in 2018 for aggravated assault. After his mother posted bail on the new charges, a probation detainer from the 2015 case kept him in custody. He later pleaded guilty to aggravated assault in the 2018 case and was sentenced to a term of imprisonment. The trial court did not credit him for all the time he spent in custody before sentencing, specifically the period he was held solely on the probation detainer after bail was posted in the 2018 case.The Lackawanna County Court of Common Pleas, acting as the PCRA court, granted partial relief by awarding credit only for the period after the detainer was lifted, reasoning that the earlier period of confinement was solely due to the probation detainer in the 2015 case, for which only a probationary sentence was ultimately imposed. The Pennsylvania Superior Court affirmed, holding that the appellant was not entitled to credit for time spent in custody on the probation detainer because no prison sentence was imposed in the 2015 case, and the time was not attributable to the new charges after bail was posted.The Supreme Court of Pennsylvania reviewed the statutory language of 42 Pa.C.S. § 9760(1) and held that a defendant is entitled to credit against a new prison sentence for all time spent in custody as a result of the conduct underlying the new charge, even if the confinement was due to a probation detainer from an earlier case, so long as the conduct leading to the detainer is the same as that underlying the new charge. The Court reversed the Superior Court’s order and remanded for further proceedings to determine if relief could still be awarded. View "Commonwealth v. Phillips" on Justia Law

Two individuals, Mario Cabral and Vanessa Mora, were shot and killed in their home in March 2018. The defendant, who had a child with Cabral and was involved in a contentious custody dispute, was accused of hiring a hitman, Edward Alonso, to kill Cabral. Alonso testified that the defendant offered him money and provided details about Cabral’s residence, but he ultimately did not carry out the murder. The prosecution presented circumstantial evidence, including testimony about the defendant’s acquisition of a .45-caliber gun, photographs of Cabral’s home found on her phone, and statements suggesting her boyfriend, Flores, might commit the murder if Alonso did not. The defendant denied involvement, but the jury convicted her of first-degree murder of Cabral, conspiracy to commit first-degree murder, and criminal solicitation of first-degree murder.The case was tried in the District Court of Doña Ana County, where the defendant objected to the prosecution’s cross-examination about her six-month-old child’s positive methamphetamine test, arguing lack of notice and relevance. The district court allowed limited questioning on this topic. The jury acquitted the defendant of Mora’s murder but convicted her on the other charges.On direct appeal, the Supreme Court of the State of New Mexico reviewed the evidentiary ruling and found that the district court abused its discretion by admitting the inquiry into the child’s drug test, as it was inadmissible under the relevant evidence rules and not justified as rebuttal character evidence. The error was deemed not harmless, given its impact on the defendant’s credibility. The Supreme Court reversed all convictions and remanded for a new trial. The court also held that the convictions for conspiracy and solicitation did not violate double jeopardy and that sufficient evidence supported the murder conviction. Additionally, the court emphasized the public’s First Amendment right to access criminal trials, criticizing the district court’s prohibition of notetaking by observers. View "State v. Cardenas" on Justia Law

A deadly shooting occurred at a house party in Las Cruces, New Mexico, in July 2021. During a chaotic altercation, multiple gunshots were fired, resulting in the death of Nicodemus Gonzales and damage to a vehicle driven by Jayissa Borrunda. Eyewitnesses described seeing the defendant and his cousin brandishing guns with laser sights. Forensic evidence was inconclusive as to which weapon caused the fatal injury. The defendant, who was seventeen at the time, was charged as a Serious Youthful Offender with first-degree (willful and deliberate) murder and other related offenses.The District Court of Doña Ana County acquitted the defendant of first-degree (willful and deliberate) murder but allowed the case to proceed to the jury on first-degree felony murder, predicated on aggravated assault, as well as other charges. The jury convicted the defendant of first-degree felony murder (as an accomplice to aggravated assault), aggravated assault, two counts of conspiracy, and shooting at a motor vehicle. The court imposed a thirty-year sentence for felony murder, an enhanced sentence for aggravated assault, and additional concurrent sentences for the other convictions.The Supreme Court of the State of New Mexico reviewed the case. It held that aggravated assault is a noncollateral felony and cannot serve as the predicate for felony murder; therefore, the defendant’s felony murder conviction must be vacated as a legal nullity. The Court further held that double jeopardy does not bar retrial for felony murder or its lesser-included offenses when a conviction is reversed for a nonexistent crime, as this constitutes trial error rather than an acquittal. The Court also vacated one conspiracy conviction for lack of evidentiary support and reversed the four-year firearm enhancement as unauthorized by statute. The remaining convictions were affirmed, and the case was remanded for further proceedings consistent with the opinion. View "State v. Revels" on Justia Law

A woman who served as the co-leader of a religious group in rural New Mexico was charged with multiple crimes after a twelve-year-old child, E.M., died at the group’s compound. The woman exercised strict control over the group’s members and limited their access to outside medical care. E.M. became seriously ill, was denied food as punishment, and ultimately died after his condition worsened. The child’s death was not reported to authorities until two years later, when other group members alerted police. An autopsy determined the cause of death was a probable infectious disease, but the exact cause could not be identified due to decomposition.The woman was initially indicted on several charges involving two children. The charges relating to another child, M.G., were severed, and she was convicted by a jury on those counts, receiving a 72-year sentence. Shortly after, she entered a plea agreement on the E.M.-related charges, including child abuse resulting in great bodily harm, and was sentenced to 18 years to run concurrently. Later, the M.G.-related convictions were set aside due to a Brady violation, and those charges were dismissed. The woman then filed a habeas petition seeking to vacate her plea in the E.M. case, arguing actual innocence, among other grounds. The district court rejected most claims but granted relief on actual innocence, finding her conduct did not legally constitute great bodily harm.The Supreme Court of the State of New Mexico held that a defendant convicted by plea agreement may assert a freestanding claim of actual innocence, applying the same clear and convincing evidence standard as for convictions after trial. However, the Court found that the district court’s determination of actual innocence was not supported by substantial evidence, as no new affirmative evidence was presented and the district court’s own findings implicated the defendant in the crime. The Supreme Court reversed the grant of habeas relief and remanded the case. View "State v. Green" on Justia Law

A Nigerian citizen who became a lawful permanent resident of the United States in 2005 was placed in removal proceedings after being convicted of conspiracy to commit passport fraud. He had lived in the U.S. for many years, had a long-term partner, and was the father of four U.S. citizen children. His conviction stemmed from a scheme to obtain fraudulent U.S. passports for noncitizens, for which he was sentenced to 27 months in prison. After serving his sentence and briefly fleeing to Canada, he was returned to the U.S. and charged as inadmissible for committing a crime involving moral turpitude. In removal proceedings, he applied for asylum, withholding of removal, and protection under the Convention Against Torture (CAT), claiming past persecution and fear of future harm in Nigeria due to his former union activities and threats from a militia group.An Immigration Judge (IJ) found him inadmissible, denied all forms of relief, and determined that his conviction constituted a particularly serious crime, barring asylum and withholding. The IJ also found his and his partner’s testimony not credible and denied CAT relief, concluding he had not shown a likelihood of torture with government acquiescence. The Board of Immigration Appeals (BIA) affirmed, agreeing with the IJ’s findings and further holding that the absence of an interpreter did not violate due process, that the conviction was a particularly serious crime, and that he was not eligible for a waiver of inadmissibility.The United States Court of Appeals for the Third Circuit reviewed the case. The court held that the BIA misapplied the legal standard for determining a particularly serious crime by failing to consider the elements of the underlying substantive offense in the conspiracy conviction. The court also found that the BIA did not properly analyze the CAT claim under the required legal framework and failed to consider eligibility for a waiver of inadmissibility. The court denied the due process claim but vacated the BIA’s decision and remanded for further proceedings, ordering a stay of removal pending the outcome. View "Amos v. Attorney General United States of America" on Justia Law

The case concerns a man who was convicted of first degree murder with a deadly weapon enhancement and resisting and obstructing an officer after his uncle was found fatally stabbed in the home they shared. The defendant was located by police shortly after the incident, with injuries and physical evidence linking him to the crime. During jury selection, the only Black juror in the venire was removed by the prosecution using a peremptory strike, prompting the defendant, who is also Black, to raise a Batson challenge alleging racial discrimination. The trial court denied the challenge, finding the State’s reasons for the strike—juror distraction due to personal circumstances and apparent disengagement—were race-neutral and not pretextual. The jury ultimately found the defendant guilty, and he was sentenced to 40 years to life.The Idaho Court of Appeals affirmed the conviction, holding that the defendant had not established a prima facie case of discriminatory intent under Batson v. Kentucky. The defendant then sought review by the Supreme Court of the State of Idaho, arguing that the trial court erred in denying his Batson challenge, limiting cross-examination about alternate perpetrators, and restricting his closing argument. He also invoked the doctrine of cumulative error.The Supreme Court of the State of Idaho clarified that, under Hernandez v. New York, once the prosecution offers a race-neutral explanation and the trial court rules on discriminatory intent, the initial prima facie showing under Batson is moot. The court found no clear error in the trial court’s acceptance of the State’s race-neutral reasons for the peremptory strike. The court also held that the trial court did not abuse its discretion in limiting cross-examination or closing argument, and found no cumulative error. The judgment of conviction was affirmed. View "State v. Buck" on Justia Law

Daniel Jackson was stopped by sheriff’s deputies in Kentucky after they observed his truck with an obscured license plate and learned he was driving without a valid license or registration. After arresting Jackson, deputies searched his truck and found methamphetamine, marijuana, syringes, and digital scales. A subsequent search of the police cruiser’s back seat, where Jackson had been placed, revealed a bag containing fentanyl. Jackson was charged with possession of fentanyl and methamphetamine with intent to distribute.The United States District Court for the Eastern District of Kentucky presided over Jackson’s trial. At trial, Jackson testified that he had been framed by a deputy who allegedly planted the drugs in both his truck and the police cruiser. The jury rejected Jackson’s account and convicted him. At sentencing, the district court found that Jackson’s testimony constituted perjury and applied a two-level obstruction-of-justice enhancement under the Sentencing Guidelines. The court also imposed a five-year term of supervised release, including a condition permitting searches of Jackson’s electronic devices by the probation office. Jackson did not object to this condition at sentencing.On appeal, the United States Court of Appeals for the Sixth Circuit reviewed Jackson’s challenges to both the obstruction-of-justice enhancement and the supervised-release search condition. The court held that the district court’s findings of perjury—falsity, willfulness, and materiality—were not clearly erroneous and that the enhancement was mandatory under the Guidelines. The appellate court also found no plain error in the imposition or explanation of the electronic-device search condition, given the district court’s stated concerns about officer safety and recidivism. Accordingly, the Sixth Circuit affirmed the judgment of the district court. View "United States v. Jackson" on Justia Law

In 2009, after a history of domestic violence and threats, the defendant killed his wife and five young children by cutting their throats and then fled to Haiti, where he was apprehended and confessed. He attributed his actions to “bad spirits” and voodoo spells. Upon return to Florida, he pled guilty to six counts of first-degree murder, waived his right to a penalty-phase jury, and declined to present mitigation evidence. Throughout the proceedings, his competency to stand trial was repeatedly evaluated, with findings alternating between competent and incompetent, but ultimately he was found competent at the time of his plea and sentencing. His defense team, which included both public defenders and later court-appointed attorneys, conducted extensive mitigation investigations, including mental health and cultural background assessments, despite the defendant’s lack of cooperation.The Circuit Court for Collier County imposed six death sentences, finding multiple aggravating factors and twelve mitigating factors, including some evidence of mental illness. On direct appeal, the Supreme Court of Florida affirmed the convictions and sentences, rejecting claims regarding self-representation, aggravator duplication, and the constitutionality of the death penalty. The defendant then filed a motion for postconviction relief under Florida Rule of Criminal Procedure 3.851, raising claims of ineffective assistance of counsel regarding competency and mitigation, and challenging restrictions on access to public records. The circuit court denied all claims after an evidentiary hearing.The Supreme Court of Florida reviewed the appeal from the denial of postconviction relief and a related habeas corpus petition. The court held that claims regarding competency were procedurally barred, as they could have been raised on direct appeal, and that the defendant failed to show ineffective assistance of counsel under the Strickland standard. The court also found no abuse of discretion in the denial of public records requests and rejected the habeas petition alleging ineffective assistance of appellate counsel. The denial of postconviction relief and the habeas petition were affirmed. View "Damas v. State of Florida" on Justia Law

A member of the Lowell police department’s gang unit created an undercover Snapchat account using a “nonwhite” username and bitmoji, aiming to monitor gang activity by befriending users connected to other officers’ undercover accounts. The officer became “friends” with a user believed to be the defendant, though he did not know the user’s identity or race at the time. The defendant posted a video of himself discharging a firearm from a car, which led police to identify and locate him. A search of the defendant’s vehicle uncovered a firearm matching the one in the video and shell casings consistent with those found at the scene. The defendant did not possess a license to carry a firearm.The Lowell Division of the District Court Department charged the defendant with multiple firearms offenses. The defendant sought discovery on a selective enforcement claim, and the court ordered the production of relevant police records and policies. The records showed that all suspects charged from Snapchat investigations with identifiable race were nonwhite. The defendant moved to suppress evidence, arguing racial motivation in the investigation, but a District Court judge denied the motion, finding no reasonable inference of racial motivation. The defendant also moved to dismiss the firearms charges, claiming the resident firearm licensing scheme violated the Second Amendment. Another District Court judge denied this motion, finding the problematic provision severable. The defendant entered conditional guilty pleas, reserving his right to appeal.The Supreme Judicial Court of Massachusetts reviewed the case. It held that the defendant had raised a reasonable inference of selective enforcement under the Commonwealth v. Long framework and remanded for an evidentiary hearing, requiring the Commonwealth to rebut the inference with a race-neutral reason. The court also held that the Commonwealth’s resident firearm licensing scheme was not facially unconstitutional under the Second Amendment, affirming the denial of the motion to dismiss. View "Commonwealth v. Rodriguez" on Justia Law

The defendant was convicted of second-degree murder following the disappearance of his former girlfriend, who was last seen at his apartment on January 12, 2014. The defendant claimed she left his apartment that night to be picked up by her son, but her son denied this, and she was never seen again. Evidence at trial included testimony about her abrupt disappearance, her close relationships, and her uncharacteristic lack of contact and financial activity after that date. Investigators presented circumstantial evidence, including electronic records showing her phone accessed social media from the defendant’s IP address after the time he claimed she left, and testimony about the defendant’s behavior following her disappearance.The Circuit Court of the Second Circuit initially dismissed a 2019 indictment without prejudice, but a second grand jury indicted the defendant in December 2020. The defendant moved to dismiss the second indictment, arguing insufficient evidence, juror bias, and excessive hearsay, but the circuit court denied the motion, finding probable cause. The court also denied motions to suppress the defendant’s police interview and his subscriber name obtained via subpoena, allowing only his name into evidence. At trial, the jury found the defendant guilty, and post-verdict motions for acquittal or a new trial were denied. The defendant appealed to the Intermediate Court of Appeals, raising multiple points of error, and the case was transferred to the Supreme Court of Hawaiʻi.The Supreme Court of Hawaiʻi affirmed the conviction, holding that there was sufficient evidence to support the verdict, the circuit court did not err in admitting the defendant’s statement to police or his subscriber name, and the claims of prosecutorial misconduct, plain error in jury instructions, defects in the indictment, and pre-indictment delay were not established. The court found no abuse of discretion or reversible error in the lower court’s rulings. View "State v. Brown" on Justia Law