Justia Criminal Law Opinion Summaries

In the early morning hours, a Metropolitan Police officer in Washington, D.C., responded to a radio dispatch about a suspicious vehicle at a specific location. Upon arrival, the officer observed two individuals fleeing from the car without any apparent provocation, leaving at least one car door open. The driver, R.W., then began to back the car out of its parking space with the rear door still open. The officer ordered R.W. to put his hands up and subsequently recovered evidence leading to charges including unauthorized use of a motor vehicle and felony receipt of stolen property.The Superior Court of the District of Columbia conducted a suppression hearing and denied R.W.’s motion to suppress, finding that the officer had reasonable suspicion based on the dispatch, the passengers’ flight, the late hour, and the car’s movement. After a bench trial, the court adjudicated R.W. delinquent on all counts. On appeal, the District of Columbia Court of Appeals reversed the suppression ruling and vacated the adjudication. It held that the officer lacked reasonable suspicion, after discounting the dispatch and the companions’ flight as relevant factors.The Supreme Court of the United States reviewed the case and held that the officer did have reasonable suspicion to stop R.W. The Court emphasized that the totality-of-the-circumstances test must be used, and that the Court of Appeals erred by disregarding key facts, such as the dispatch and the passengers’ flight, from its analysis. The Supreme Court reversed the judgment of the District of Columbia Court of Appeals and remanded the case for further proceedings consistent with its opinion. The holding is that, under the totality of the circumstances, the officer’s stop was supported by reasonable suspicion as required by the Fourth Amendment. View "District of Columbia v. R.W." on Justia Law

A man was convicted in 2012 of felony murder following the death of a two-year-old child for whom he was the primary caretaker. The child had suffered severe head injuries consistent with nonaccidental trauma and was pronounced brain dead after being transported to a hospital. Law enforcement interviewed the man, who was advised of his Miranda rights and did not confess but offered alternative explanations for the injuries. He received a 100-year sentence without parole.After his conviction, the man filed a petition for postconviction relief in the Montana Eighth Judicial District Court, primarily alleging ineffective assistance of counsel on several grounds, including failure to move to suppress his statements to police, not hiring an independent medical expert, conceding in closing argument that the child’s injuries were not accidental, and not allowing him to testify. Initially denied without counsel, the case was remanded for appointment of counsel and a new hearing. With counsel, he renewed his claims and added an allegation that the State had not produced certain discovery related to a drug investigation at the residence. After a second evidentiary hearing, the District Court denied all claims, finding either they were procedurally barred, unsupported by evidence, or reflected reasonable trial strategy.On appeal, the Supreme Court of the State of Montana reviewed the District Court’s findings for clear error and its legal conclusions de novo. Applying the two-prong test from Strickland v. Washington, the Supreme Court held that the man failed to demonstrate deficient performance by either his trial or appellate counsel, or resulting prejudice. The Court found that counsel’s actions were reasonable strategic decisions under the circumstances and that no meritorious claims for ineffective assistance or other postconviction relief were established. Accordingly, the Supreme Court affirmed the District Court’s denial of the petition. View "Hyslop v. State" on Justia Law

The defendant was arrested in October 2021 and charged with robbery and disorderly conduct. Initial proceedings raised concerns about his mental fitness, and he was evaluated at Montana State Hospital. Multiple evaluations between December 2021 and April 2023 determined that he was unfit to proceed, largely due to his refusal to take medication. In October 2022, the court authorized involuntary medication following a Sell v. United States hearing. By April 2023, the defendant was found fit to proceed, and at a subsequent hearing, he was arraigned and entered a plea of not guilty to both charges. In July 2023, a plea agreement was reached where the defendant pleaded guilty to attempted robbery in exchange for dismissal of the disorderly conduct charge.The Fourth Judicial District Court accepted the defendant’s guilty plea after confirming it was entered voluntarily, knowingly, and intelligently. At the change of plea hearing, the defendant expressed concern about a potential speedy trial violation and asked to have it noted for the record. The court acknowledged the statement but declined to accept briefing on the issue, and neither the defendant nor his counsel filed a motion or objected further. The defendant was subsequently sentenced to ten years, with credit for time served.On appeal, the Supreme Court of the State of Montana considered whether the lower court abused its discretion by refusing to accept briefing on the speedy trial issue and whether the issue was preserved for review. The Supreme Court held that by voluntarily and knowingly pleading guilty without first obtaining an adverse ruling on a timely filed motion, the defendant waived all nonjurisdictional defects, including claims of speedy trial violations. The Court also declined to review the claim under the plain-error doctrine, finding no manifest miscarriage of justice. The judgment was affirmed. View "State v. Hill" on Justia Law

Police investigated a domestic disturbance in December 2020 involving the appellant, who was subsequently charged in Yellowstone County, Montana, with his fourth DUI-related offense. The State later amended the charges to include DUI per se for operating a noncommercial vehicle with a blood alcohol concentration of 0.08 or more, fourth or subsequent offense. The appellant entered a plea agreement, pleading guilty to the amended charge in exchange for dismissal of the original DUI charge. At sentencing, both parties recommended specific incarceration and treatment conditions, and agreed to a $5,000 fine. The appellant requested that certain fees be waived due to his financial circumstances.The Thirteenth Judicial District Court accepted the plea, dismissed the original charge, and imposed the recommended sentence, including the mandatory-minimum $5,000 fine under § 61-8-731(1)(a)(iii), MCA (2019). The court also orally stated it would waive several fees. However, the written judgment subsequently entered required the appellant to pay a variety of fees and surcharges, contrary to the oral pronouncement. The appellant appealed, arguing that the mandatory fine was unconstitutional and that the imposition of fees conflicted with the oral pronouncement.The Supreme Court of the State of Montana reviewed the case. Guided by its recent decision in State v. Cole, the Court held that sentencing courts must consider a defendant’s ability to pay when imposing the mandatory-minimum fine and may suspend the portion a defendant is unable to pay. Because the District Court made no findings regarding the appellant’s ability to pay, the Supreme Court reversed the fine and remanded for further proceedings consistent with Cole. The Court also ordered the written judgment to be amended to conform to the fees waived in open court. View "State v. C. Horn" on Justia Law

The defendant participated in a mental health diversion program after being charged in several separate incidents with burglary, theft, and related offenses. She entered various facilities, including hospitals and senior living residences, often under false pretenses, to steal personal property from employees, residents, and others. After being granted diversion, she was required to abstain from drug use, comply with treatment, and avoid committing new crimes. However, during the diversion period, the defendant relapsed into drug use, declined further treatment, and was charged with over 40 new offenses, many similar to her prior conduct.The Santa Clara County Superior Court, despite acknowledging these ongoing violations, found that the defendant had successfully completed diversion. The court based this conclusion on her exemplary conduct and progress during a subsequent period of custody, including active engagement in treatment and rehabilitation programs. As a result, the court dismissed the original charges and granted diversion on newer charges.The California Court of Appeal, Sixth Appellate District, reviewed the trial court’s decision. The appellate court held that, under Penal Code section 1001.36, a trial court may only find satisfactory completion of mental health diversion if the defendant has substantially complied with the requirements of diversion, including refraining from significant new law violations. Because the defendant repeatedly committed new crimes and failed to comply with diversion requirements, the appellate court concluded that the trial court abused its discretion in dismissing the charges. The court reversed the order dismissing the charges and remanded the case for further proceedings on those charges. View "P. v. Landrine" on Justia Law

A man who entered the United States illegally as a teenager from Mexico was later abused and threatened by an older woman, an American citizen, who orchestrated his entry. According to the man, he was held by her associates upon arrival, threatened with harm if he disobeyed, and subjected to years of physical, emotional, and psychological abuse while living with her in Oklahoma. He had some contact with family, but the woman restricted his movements and threatened to harm him or his family if he did not comply. After being arrested and deported in 2013, he was allegedly kidnapped by the same associates, beaten, and brought back to the U.S., where the abuse continued for another decade. In 2023, he escaped, obtained a protective order, and sought counseling, but the woman allegedly continued to harass and threaten him and his family.Following his arrest in 2024 after a domestic incident, he was indicted in the United States District Court for the Northern District of Oklahoma for Unlawful Reentry of a Removed Alien under 8 U.S.C. § 1326. He moved for a jury instruction on the defense of duress, arguing that he was forced to remain in the U.S. under threat of harm. The district court denied his motion, finding insufficient evidence that he lacked reasonable opportunity to escape or that he made a prompt, bona fide effort to surrender to authorities once free from coercion. He entered a conditional guilty plea, reserving his right to appeal the denial of the duress instruction.The United States Court of Appeals for the Tenth Circuit reviewed the district court’s denial for abuse of discretion. The court held that the defendant failed to present sufficient evidence to warrant a duress instruction, as he had reasonable opportunities to escape and did not promptly surrender to authorities once he was no longer under immediate threat. The court affirmed the district court’s judgment. View "United States v. Carpena" on Justia Law

Shahriyar Bolandian was convicted of insider trading based on allegations that he traded on nonpublic information regarding the mergers of two companies, information allegedly obtained from a friend, Ashish Aggarwal, who worked at J.P. Morgan. Bolandian executed trades in the stocks of PLX Technologies and ExactTarget before their respective acquisitions, ultimately earning substantial profits. These trades occurred while Aggarwal, though not assigned to the deals, worked in the relevant banking group. The case revolved around whether Aggarwal had improperly shared confidential information, and whether Bolandian knowingly traded on it.Initially, the United States District Court for the Central District of California severed Aggarwal’s trial from that of Bolandian and another co-defendant, Sadigh, due to the risk of antagonistic defenses. Aggarwal was ultimately acquitted by a jury. Afterward, a superseding indictment charged only Bolandian and Sadigh, and eventually Bolandian alone proceeded to trial. During Bolandian’s trial, a juror (Juror No. 6) expressed uncertainty about his ability to be impartial due to a family connection to J.P. Morgan. The district court questioned Juror No. 6 briefly, but allowed him to remain on the jury after both parties did not object.The United States Court of Appeals for the Ninth Circuit reviewed Bolandian’s conviction and focused on the issue of juror bias. The court held that the district court failed in its independent duty to investigate credible allegations of juror bias after Juror No. 6 expressed doubt about his impartiality. The panel concluded that defense counsel’s agreement to keep Juror No. 6 did not waive Bolandian’s right to challenge for bias, as a proper investigation is a prerequisite to waiver. The Ninth Circuit found plain error, vacated Bolandian’s conviction, and remanded for a new trial. View "USA V. BOLANDIAN" on Justia Law

Between 2017 and 2021, a man sexually abused a minor, the daughter of his girlfriend, in various locations within Indian country in Oklahoma. The abuse came to light after the victim reported it to a school counselor, triggering investigations by state, tribal, and federal authorities. The locations of the abuse included areas within the Cherokee and Muscogee (Creek) Reservations.Initially, the State of Oklahoma charged the defendant in state court as a non-Indian, and the Cherokee Nation filed charges against him in tribal court as an Indian for the same conduct. The defendant sought dismissal of the state prosecution, claiming Indian status, and, in the tribal prosecution, claimed he was not an Indian. Subsequently, a federal grand jury indicted him on four counts: two under 18 U.S.C. § 1152 (as a non-Indian defendant with an Indian victim), and two under 18 U.S.C. § 1153 (as an Indian defendant). The defendant moved to dismiss the indictment as multiplicitous or to require the government to elect the theory of prosecution. The United States District Court for the Northern District of Oklahoma denied these motions and allowed the case to proceed to trial, instructing the jury to convict under only one statutory regime, not both.The United States Court of Appeals for the Tenth Circuit reviewed the case. The court held that there was sufficient evidence for a rational jury to find beyond a reasonable doubt that the victim was an Indian and that the defendant was a non-Indian at the time of the offenses. The court also held that the district court did not abuse its discretion by permitting alternative charges to go to the jury, so long as the instructions prevented multiplicitous convictions. The court affirmed the defendant’s convictions. View "United States v. King" on Justia Law

The case concerns a defendant who, in December 2017, detonated a homemade pipe bomb in a crowded pedestrian tunnel connecting the Times Square subway station and the Port Authority Bus Terminal in Manhattan. The defendant, motivated by propaganda from a foreign terrorist organization, constructed the device using materials from his workplace and filled it with metal screws to act as shrapnel. On the morning of the attack, he strapped the bomb to his body, rode the subway into Manhattan, and triggered the device during rush hour, injuring himself and several bystanders. The attack caused both physical and psychological harm to victims and created a significant risk to public safety.The United States District Court for the Southern District of New York presided over the trial. After a jury convicted the defendant on six counts—including providing material support to a foreign terrorist organization, committing a terrorist attack on mass transportation, and using a destructive device during a crime of violence—the court denied the defendant’s motions for acquittal and imposed sentences including multiple life terms plus an additional thirty years. The defendant appealed his convictions on three counts and challenged the reasonableness of his sentence.The United States Court of Appeals for the Second Circuit reviewed the case. The court found insufficient evidence to support the conviction for providing material support to a foreign terrorist organization, as the defendant acted independently and not under the direction or control of that organization. Consequently, the court reversed the conviction on that count. The court affirmed the convictions for committing a terrorist attack against mass transportation and for using a destructive device during a crime of violence, finding the evidence sufficient and any possible legal errors harmless. The court also upheld the reasonableness of the sentence. The case was remanded for further proceedings consistent with these rulings. View "United States of America v. Ullah" on Justia Law

The defendant engaged in a scheme from 2017 through 2020 in which he impersonated an attorney to obtain personally identifiable information from prisoners. Using this information, he filed unauthorized tax returns in the names of at least nine prisoners, receiving $136,672 in fraudulent refunds from the Internal Revenue Service. At the time of his arrest, the defendant was already under community supervision for a similar offense and had a significant criminal history, including prior convictions for fraud-related and other offenses.A grand jury in the United States District Court for the Southern District of New York indicted the defendant on multiple fraud and theft charges. He pleaded guilty to fourteen counts of making false claims and one count of theft of government funds. The district court sentenced him to forty-six months in prison, three years of supervised release, and ordered forfeiture and restitution. The supervised release included standard and special conditions, one of which allowed for electronic monitoring of all devices capable of accessing the internet, unannounced examinations of such devices, and monitoring of any work-related devices as permitted by his employer. The defendant did not object to these conditions at sentencing but challenged them on appeal.The United States Court of Appeals for the Second Circuit reviewed the case. It held that the district court did not err in imposing the special condition of electronic monitoring. The appellate court found the condition was reasonable in light of the nature of the offenses and the defendant’s history, was not overbroad, and did not amount to an impermissible occupational restriction under the Sentencing Guidelines. The court concluded that the monitoring requirements did not prohibit the defendant from pursuing any occupation and were necessary to protect the public. The judgment of the district court was affirmed. View "United States v. Brown" on Justia Law