Justia Criminal Law Opinion Summaries

Three individuals were involved in a conspiracy to rob a marijuana dealer at his home on the Big Cypress Seminole Indian Reservation. During the attempted robbery, a bystander was shot and killed, and the perpetrators fled without obtaining money or drugs. One of the defendants later discussed the crime with a third party, who reported the information to law enforcement and recorded a conversation, further implicating the participants. Additional evidence, including surveillance footage, cell site records, and ballistics, corroborated the involvement of the defendants.The United States District Court for the Middle District of Florida heard the case. One defendant moved to dismiss the indictment, arguing that because both he and the victim were enrolled members of Indian tribes and the offense occurred in Indian country, and since the charged crimes were not listed in the Major Crimes Act, the court lacked jurisdiction. The district court disagreed and denied the motion, allowing the prosecution to proceed. During trial, another defendant objected to the admission of prior convictions without an explicit balancing of probative value and prejudicial effect. The court admitted the evidence without making such a finding. The jury ultimately found the defendants guilty on various counts, and the defendants appealed.The United States Court of Appeals for the Eleventh Circuit reviewed the case. It held that federal courts possess jurisdiction over generally applicable federal crimes, such as Hobbs Act robbery, even when committed by an Indian against another Indian in Indian country. The court also found that the district court erred by not conducting an on-the-record balancing before admitting evidence of prior convictions, but deemed this error harmless given the strength of the government’s case. The convictions of all three defendants were affirmed. View "USA v. Brice" on Justia Law

The case concerns two individuals who previously worked for a consulting firm that provided proprietary software to several state agencies. After leaving the company, they joined a competitor and helped secure a contract to develop similar software for other states. In 2016, a whistleblower alleged that the defendants' new employer was using materials misappropriated from their former company. This triggered a multi-agency federal investigation that lasted approximately six years. By the time charges were brought, two potentially significant witnesses had died, and several state agencies had destroyed documents that might have been relevant to the defense.The United States District Court for the Southern District of West Virginia, after the defendants moved to dismiss, found that the loss of the witnesses' testimony and the destruction of documents resulted in substantial prejudice to the defendants. The district court concluded that the government's lengthy investigation did not sufficiently justify the preindictment delay, given the prejudice to the defense, and dismissed ten out of fourteen counts in the superseding indictment on due process grounds. The government appealed this dismissal.The United States Court of Appeals for the Fourth Circuit reviewed the case and held that, even assuming the defendants suffered actual and substantial prejudice, the government's preindictment delay was the result of a good faith, ongoing investigation and not motivated by bad faith or an attempt to gain a tactical advantage. The Fourth Circuit clarified that investigative delay, without improper motive, does not violate due process, even if it results in prejudice to the defendant. The court reversed the district court’s dismissal of the counts and remanded the case for further proceedings on all counts. View "US v. Minkkinen" on Justia Law

A cable company employee discovered the appellant at his apartment with blood on his face, neck, and clothing, requesting police assistance after an incident involving his girlfriend. When officers arrived, they found the victim, Debra Shirron, dead in bed with visible injuries. The appellant was charged with first-degree murder of a victim 60 years of age or older and abuse of an older/vulnerable person resulting in substantial bodily or mental harm or death. At trial, the appellant claimed legal insanity and self-defense, citing a recent traumatic brain injury and consumption of marijuana brownies prior to the incident. Expert testimony presented conflicting views on whether the appellant’s delusions and violent behavior were caused by his brain injury, voluntary intoxication, or a combination of both.The Eighth Judicial District Court in Clark County presided over the trial. During the proceedings, the court allowed a replacement medical examiner to testify to possible causes of death beyond blunt force trauma, including asphyxiation and strangulation, without prior notice to the defense. The appellant objected to jury instruction 17, which addressed voluntary intoxication in relation to the insanity defense, arguing it conflicted with the legal definition of insanity. The objection was preserved, but the court overruled it. The jury convicted the appellant on both counts.The Supreme Court of the State of Nevada reviewed the case. The Court held that the district court erred by instructing the jury that voluntary intoxication could not be considered as part of an insanity defense unless it was not a contributing factor, which contradicted statutory law. The error was not harmless, as it likely had a substantial effect on the verdict. The Court reversed the conviction and remanded the case for further proceedings. It also clarified that expert testimony at trial must be disclosed in accordance with statutory requirements. View "AUBRY VS. STATE" on Justia Law

Law enforcement responded to an incident where the defendant, after brandishing a machete and robbing a 76-year-old man of his car, led police on a dangerous high-speed chase. He drove on the wrong side of major roads and ignored traffic signals before being apprehended. At the time, he had deliberately stopped taking prescribed mental health medication. He was charged with robbery of an elderly person, grand larceny of a motor vehicle, and driver evading or failing to stop for a police signal in a manner endangering others.A jury in the Second Judicial District Court in Washoe County found him not guilty by reason of insanity (NGRI) for the robbery and grand larceny counts but guilty but mentally ill (GBMI) for the driver-evading count. Following the verdicts, the district court ordered a mental health evaluation and held a hearing pursuant to NRS 175.539. The defendant argued that the court was required to commit him to a forensic mental health facility for treatment before sentencing on the GBMI conviction, or at minimum, impose probation conditioned on such treatment. The district court rejected this argument, concluding that the statutes did not require commitment before sentencing and that it retained discretion to impose a prison sentence for the GBMI conviction, with treatment during incarceration and civil commitment following release if necessary.On appeal, the Supreme Court of Nevada affirmed the district court’s judgment. The Court held that Nevada statutes do not specify the sequence of civil commitment and criminal sentencing in cases with both NGRI acquittals and a GBMI conviction. Therefore, the district court retains discretion to sentence a defendant to prison for a GBMI conviction, with appropriate mental health treatment during incarceration, and to order evaluation for civil commitment after release. Probation is not mandatory in split-verdict cases. The judgment of conviction was affirmed. View "SILVANUS VS. STATE" on Justia Law

David Lopez, Jr. pleaded guilty to two counts of transportation of child pornography and two counts of possession of child pornography. He participated in online chatrooms where access to child pornography was conditioned on submitting such images to the group. These chatrooms required frequent submission of materials to avoid expulsion as a “lurker.” Upon his conviction, the district court relied on the presentence investigation report, which concluded that Lopez’s conduct warranted sentencing enhancements, including a five-level increase for distributing child pornography in exchange for valuable consideration (but not for pecuniary gain) and another five-level increase for engaging in a pattern of activity involving the sexual abuse or exploitation of a minor.The United States District Court for the Southern District of Texas imposed both enhancements, resulting in an offense level of forty-two and a criminal history category of V, with a Guidelines range of 360 months to life imprisonment. The court sentenced Lopez to 360 months, the low end of the Guidelines range, with concurrent sentences for all counts and a life term of supervised release. Lopez timely appealed, disputing both enhancements.The United States Court of Appeals for the Fifth Circuit reviewed the application of the enhancements. The appellate court held that the district court properly applied the distribution enhancement because evidence supported that Lopez implicitly agreed to exchange child pornography with chatroom participants to obtain more such material. However, the appellate court found that the district court plainly erred in applying the pattern enhancement, as Lopez’s convictions and prior state offense did not establish two qualifying instances of sexual abuse or exploitation. The Fifth Circuit vacated Lopez’s sentence and remanded the case for resentencing, instructing the district court to reconsider the pattern enhancement and addressing whether new evidence may be presented. View "USA v. Lopez" on Justia Law

A man was found shot and killed on a snow-covered trail in Saint Louis County, Minnesota. The investigation quickly focused on three individuals: the appellant, his girlfriend, and another accomplice. Key evidence included the murder weapon, Facebook messages discussing plans to harm the victim, and DNA on the weapon matching the appellant. The girlfriend, who was an eyewitness, testified to having seen the appellant shoot the victim. Law enforcement obtained a warrant to search multiple Facebook accounts—those of the appellant, his girlfriend, and the other accomplice—uncovering messages implicating the appellant.After initially pleading guilty to first-degree murder, the appellant challenged the conviction in postconviction proceedings. The Minnesota Supreme Court in Bonnell v. State vacated the guilty plea, remanding the case for trial. Before trial, the appellant moved to suppress evidence from the Facebook searches, arguing that the warrant lacked specificity. The Saint Louis County District Court denied the motion and admitted the evidence at trial, over defense objection. The jury convicted the appellant of first-degree premeditated murder.On direct appeal, the Supreme Court of Minnesota held, as a matter of first impression, that a sender of an electronic message does not retain a reasonable expectation of privacy in a copy of the message stored in the recipient’s separate and independent account or device. Thus, the appellant’s Fourth Amendment protections were not triggered by searches of his accomplices’ Facebook accounts. However, the appellant did have a reasonable expectation of privacy in his own Facebook accounts, and the warrant authorizing those searches was invalid for lack of particularity. Despite this error, the court concluded it was harmless beyond a reasonable doubt because the remaining evidence was overwhelming. The court also found that any errors in admitting certain prior bad acts evidence were harmless. The conviction was affirmed. View "State of Minnesota vs. Bonnell" on Justia Law

During an incident in Sonoma County, the defendant aimed an unloaded firearm at police officers, racked the slide, and pulled the trigger, but the weapon did not discharge. Officers later recovered the unloaded gun from the defendant’s vehicle. The defendant was charged and convicted of knowingly resisting an executive officer by the use of force or violence, in violation of California Penal Code section 69, subdivision (a). At trial, the defendant argued that assault is a lesser included offense of resisting an officer by force or violence, and that because his firearm was unloaded, he lacked the present ability to inflict injury, precluding a conviction for assault and thus for resisting under section 69(a).The Sonoma County Superior Court denied the defendant’s motion for acquittal and declined to instruct the jury on assault as a lesser included offense. The jury convicted the defendant on one count of resisting an officer but was unable to reach a verdict on two other counts. On appeal, the California Court of Appeal, First Appellate District, Division One, affirmed the conviction. The appellate court rejected the argument that assault is a lesser included offense of resisting an officer by force or violence, reasoning that section 69 does not include the “present ability” requirement found in assault, nor does its language require force or violence to be directed “upon the person” of an officer.The Supreme Court of California reviewed the case to resolve a conflict with an earlier decision, People v. Brown. The Supreme Court held that assault is not a lesser included offense of resisting an officer by force or violence under section 69(a), because this offense does not require a present ability to cause injury. The court affirmed the judgment of the Court of Appeal and expressly disapproved People v. Brown to the extent it was inconsistent with this holding. View "P. v. Morgan" on Justia Law

The case concerns an individual who engaged in a lengthy, high-speed police chase that began after a domestic dispute in Brunswick, Cumberland County. The individual left in his girlfriend’s car without permission and was soon pursued by police, first in Sagadahoc County and then back and forth between Sagadahoc and Cumberland Counties. Throughout the chase, he drove recklessly, endangered other drivers, and ultimately collided with a police cruiser, injuring an officer. The entire pursuit was captured on video and presented at trial.A criminal complaint was filed, and a Cumberland County grand jury indicted him on several charges, including eluding an officer and reckless conduct with a dangerous weapon. After it was discovered that some conduct occurred in Sagadahoc County, the State successfully moved to amend the indictment to include both counties. The trial court, sitting as the Cumberland County Unified Criminal Docket, denied the defendant’s motion for acquittal, and the jury found him guilty of eluding an officer and reckless conduct with a dangerous weapon. He was acquitted of some other charges, and this appeal followed.The Maine Supreme Judicial Court reviewed whether the Cumberland County grand jury had the authority to indict for conduct spanning both counties and whether the evidence supported the conviction for reckless conduct with a dangerous weapon. The Court held that both crimes were continuing offenses, committed in both counties, and could be indicted in either. The Court also held that the evidence was sufficient for the jury to find that the defendant used his vehicle as a dangerous weapon. The judgment of conviction was affirmed. View "State of Maine v. Coffill" on Justia Law

Keith Merchant was indicted on eight charges related to repeated sexual offenses against his niece, which occurred over several years beginning when she was twelve years old. The offenses included two counts of gross sexual assault, three counts of unlawful sexual contact, two counts of sexual abuse of a minor, and one count of violating a condition of release. Merchant pleaded guilty to all charges. At sentencing, the court considered testimony from law enforcement and unsworn statements from the victim and her family, noting the lengthy period of abuse and Merchant’s position of trust.The Somerset County Unified Criminal Docket accepted Merchant’s guilty pleas and conducted sentencing in accordance with the three-step analysis established in State v. Hewey and codified in Maine law. The court imposed twenty years’ imprisonment for the first gross sexual assault count and a consecutive ten-year sentence, plus ten years of supervised release, for the second gross sexual assault count. The remaining sentences were set to run concurrently with the first count. Merchant filed for, and was granted, leave to appeal his sentence by the Sentence Review Panel.The Maine Supreme Judicial Court reviewed the case and determined that the sentencing court erred by applying the same sentencing analysis to both primary gross sexual assault counts but issuing different sentences for each, without providing a logical or articulated basis for the disparity. The Court held that a separate, individualized sentencing analysis was required for each primary count that was to run consecutively. Consequently, the Court vacated Merchant’s sentence and remanded the case for resentencing in accordance with its opinion, specifying that no more severe sentence could be imposed on remand. View "State of Maine v. Merchant" on Justia Law

Raymond Bright was convicted of two counts of first-degree murder after the brutal killing of two men with a hammer in his Jacksonville home. The evidence included testimony from the person who discovered the bodies, forensic evidence linking a hammer to one victim, and confessions Bright made to acquaintances. The medical examiner testified to the extreme violence of the attacks, and the jury found Bright guilty. In the penalty phase, the jury initially recommended death, which the trial court imposed. After his convictions and sentences were affirmed on direct appeal, Bright sought postconviction relief, arguing, among other things, ineffective assistance of counsel. The circuit court ultimately granted a new penalty phase due to counsel’s failure to adequately investigate mitigation evidence.During the second penalty phase, a jury unanimously recommended death for both murders after finding aggravators proven, and the trial court again imposed death sentences. Bright’s subsequent direct appeal to the Supreme Court of Florida resulted in the affirmation of his sentences. He later sought postconviction relief in circuit court, raising numerous claims, primarily ineffective assistance of counsel and procedural errors, and requested to amend his motion and interview jurors. The circuit court denied his requests as well as his substantive claims after an evidentiary hearing.The Supreme Court of Florida reviewed Bright’s appeal from the denial of his postconviction motion and his petition for writ of habeas corpus. The court held that the circuit court did not abuse its discretion in denying the amendment of his motion or the juror interviews, and that Bright failed to demonstrate either deficient performance or prejudice under the Strickland standard for any of his ineffective assistance claims. The court also denied all claims raised in the habeas petition, finding them either meritless or procedurally barred. The Supreme Court of Florida affirmed the denial of postconviction relief and denied habeas corpus. View "Bright v. State of Florida" on Justia Law