Justia Criminal Law Opinion Summaries

Ryan Bloomer was charged with his fourth DUI offense in 2021 and pleaded guilty in 2022. Before he was sentenced for this offense, he was charged with a fifth DUI in April 2023, to which he also pleaded guilty. The District Court sentenced Bloomer for both offenses during the same hearing in May 2023. For the fourth DUI, Bloomer was sentenced under the statute in effect at the time of the offense, § 61-8-731, MCA (2019), to thirteen months at the Department of Corrections (DOC) followed by a five-year suspended sentence. For the fifth DUI, he was sentenced under the new statute, § 61-8-1008(2), MCA (2021), to a concurrent nine-year term with the DOC, with five years suspended.The Fourth Judicial District Court sentenced Bloomer for both DUI offenses during the same hearing. Bloomer challenged the sentence for his fifth DUI, arguing that it was unlawful because he had not been "previously sentenced" for his fourth DUI under § 61-8-1008(1), MCA, before being sentenced for his fifth DUI under § 61-8-1008(2), MCA.The Supreme Court of the State of Montana reviewed the case. The court held that the plain language of § 61-8-1008(2), MCA, requires that a defendant must have been previously sentenced for a fourth DUI before being sentenced for a fifth DUI. Since Bloomer was sentenced for both offenses contemporaneously, the court concluded that the District Court imposed an unlawful sentence for the fifth DUI. The Supreme Court reversed the District Court's sentence for the fifth DUI and remanded the case for resentencing under § 61-8-1008(1), MCA. View "State v. Bloomer" on Justia Law

James Houston Parker was convicted in May 2023 by a jury in the Montana Eighth Judicial District Court, Cascade County, for two counts of felony tampering with or fabricating physical evidence. The charges stemmed from an incident on June 9, 2022, where officers responded to a call about an assaulted woman, P.H., who had severe facial injuries. P.H. had been at Parker's residence earlier that evening. Officers found blood and bleach at Parker's residence, and Parker had blood and bleach on his shoes. Parker was uncooperative during evidence collection, and his fingerprint was found on a bleach bottle in a nearby dumpster.The District Court instructed the jury to convict Parker based on him acting "knowingly" rather than "purposely," which Parker did not object to at trial. The jury acquitted Parker of aggravated assault but convicted him on the tampering charges. Parker was sentenced to six years in the Department of Corrections.Parker appealed to the Supreme Court of the State of Montana, arguing that the District Court committed plain error by using the incorrect mental state in the jury instructions, that his counsel was ineffective for not objecting to the instruction, and that the prosecutor's actions constituted misconduct. The Supreme Court reviewed the case and found that although the instruction was erroneous, the overwhelming evidence showed Parker acted with purpose. The court held that the error did not result in a miscarriage of justice or undermine the trial's fairness.The Supreme Court also found that Parker's ineffective assistance of counsel claim failed because there was no reasonable probability of a different outcome even if the objection had been made. Lastly, the court determined that the prosecutor did not engage in misconduct that deprived Parker of a fair trial. The Supreme Court of the State of Montana affirmed Parker's conviction. View "State v. Parker" on Justia Law

Ryan Gabriel appealed an Eleventh Judicial District Court order affirming the Justice Court’s order of protection in favor of Kai Groenke, an attorney for Gabriel’s former partner. Gabriel had sent a series of threatening and harassing emails to Groenke, including threats of professional disciplinary action, accusations of mental illness, and threats of violence. Groenke obtained a temporary order of protection, which Gabriel violated by continuing to send harassing communications.The Justice Court held a hearing where Groenke, her father Fritz, and her husband testified about Gabriel’s threatening behavior and its impact on Groenke’s mental health and safety. Gabriel argued that his communications were provoked by Groenke and that he was the victim of harassment. The Justice Court found Gabriel’s behavior to be consistent with stalking and granted a ten-year order of protection.Gabriel appealed to the District Court, which reviewed the case and affirmed the Justice Court’s decision. Gabriel then appealed to the Supreme Court of the State of Montana.The Supreme Court of the State of Montana reviewed the case and upheld the lower courts' decisions. The court found that Gabriel’s conduct met the statutory definition of stalking, causing substantial emotional distress and fear for safety. The court rejected Gabriel’s arguments about the relevance of the Oregon trial court’s stay and his claims of provocation. The court also declined to address Gabriel’s First Amendment argument, as it was raised for the first time in his reply brief. The Supreme Court affirmed the Justice Court’s order of protection. View "Groenke v. Gabriel" on Justia Law

Steven Fulton was convicted by a jury of knowingly making a false statement in connection with the attempted acquisition of a firearm. The evidence showed that Fulton denied having any felony convictions on a background check form at a gun shop in North Carolina, despite having a prior felony conviction in New Jersey. The district court overturned the jury’s verdict and entered a judgment of acquittal, reasoning that the Government did not present evidence to the jury demonstrating that Fulton’s New Jersey offense was punishable by more than a year in prison. The district court also conditionally granted Fulton a new trial in case the acquittal was reversed.The United States District Court for the Eastern District of North Carolina initially reviewed the case. The district court granted Fulton’s motion for acquittal, holding that the Government failed to prove that Fulton’s New Jersey conviction was a felony. The court reasoned that the criminal judgment did not define a third-degree offense, did not include the word “felony,” and did not identify the maximum punishment for the offense. The district court also conditionally granted a new trial, citing insufficient evidence of Fulton’s knowledge that he was a felon.The United States Court of Appeals for the Fourth Circuit reviewed the case. The appellate court reversed the district court’s judgment of acquittal, holding that the Government had introduced sufficient evidence to prove that Fulton’s New Jersey conviction was a felony punishable by more than one year in prison. The court determined that whether a crime is punishable by more than one year in prison is a legal question for the judge to determine, not a factual question for the jury. The appellate court also reversed the district court’s conditional grant of a new trial, finding that the evidence presented at trial was sufficient to support the jury’s verdict. The case was remanded with instructions to reinstate the jury’s verdict. View "US v. Fulton" on Justia Law

Ronald Myers pleaded guilty in 2005 to possessing an implement for counterfeiting state securities and transporting a stolen motor vehicle across state lines. He was sentenced to 60 months in prison, 3 years of supervised release, and ordered to pay $40,406 in restitution. Myers completed his sentence in 2010 but was reincarcerated in 2013 on other charges. Since then, over $30,500 has been deposited into his inmate trust account, mostly from family and friends, with a smaller portion from prison wages. Myers still owes over $35,000 in restitution.The United States District Court for the Eastern District of Washington granted the government's motion to turn over funds from Myers's inmate trust account to apply to his restitution obligation. The court rejected Myers's request for an evidentiary hearing to determine which funds were prison wages, concluding that the government had provided sufficient evidence of the account's composition. The court held that the Mandatory Victims Restitution Act (MVRA), 18 U.S.C. § 3664(n), applies to substantial aggregated sums from multiple sources, not just one-time financial windfalls.The United States Court of Appeals for the Ninth Circuit affirmed the district court's order. The court held that § 3664(n) applies to substantial resources from any source, including gradual accumulations from family and friends, and not just to one-time windfalls. The court also found that the district court did not abuse its discretion in declining to hold an evidentiary hearing, as the existing documentary evidence was sufficient. The court concluded that the turnover order did not contravene the judgment's restitution provisions and was consistent with the MVRA's goal of ensuring prompt restitution to victims. View "United States v. Myers" on Justia Law

Larry Householder, former Speaker of the Ohio House of Representatives, and lobbyist Matthew Borges were convicted of conspiring to solicit and receive nearly $60 million in exchange for passing a billion-dollar bailout for a failing nuclear energy company, FirstEnergy Corp. Householder used the funds to support his bid for the speakership and to recruit candidates who would vote for him. Borges played a role in the conspiracy by attempting to disrupt a referendum campaign against the bailout legislation.The United States District Court for the Southern District of Ohio at Cincinnati found both Householder and Borges guilty after a 26-day trial. Householder was convicted of multiple counts, including public-official bribery, private-citizen bribery, and money laundering. Borges was also found guilty of participating in the conspiracy.The United States Court of Appeals for the Sixth Circuit reviewed the case and found no reversible error, affirming the convictions. The court held that the evidence was sufficient to support the jury's findings that Householder and Borges engaged in a quid pro quo arrangement with FirstEnergy. The court also upheld the jury instructions, finding them consistent with applicable law, and rejected Householder's claims of insufficient evidence, right to counsel violations, and judicial bias. Additionally, the court found that the district court did not abuse its discretion in its evidentiary rulings or in admitting the guilty pleas of co-conspirators.Householder's sentence of twenty years, the statutory maximum under RICO, was deemed procedurally and substantively reasonable. The court emphasized the magnitude and severity of Householder's offense, referring to it as the "biggest corruption case in Ohio's history." Borges's arguments regarding the sufficiency of the evidence and the district court's evidentiary rulings were also rejected, and his conviction was affirmed. View "United States v. Householder" on Justia Law

The case involves Kevin Ray Ward, who was convicted of participating in a violent attack on three men returning from a fishing trip in Indian Country. After his arrest, Ward admitted to participating in the attack but claimed at trial that he did so under duress due to threats from Anthony Juan Armenta. During cross-examination, the prosecutor questioned Ward about his failure to mention these threats when initially questioned by law enforcement. The prosecutor also highlighted this omission during closing arguments to challenge Ward's credibility.The United States District Court for the Eastern District of Oklahoma convicted Ward of assault resulting in serious bodily injury, assault with a dangerous weapon with intent to do bodily harm, and use, carrying, brandishing, and discharge of a firearm during and in relation to a crime of violence. Ward did not raise the issue of his post-arrest silence being used against him during the trial, so the appellate court reviewed the case for plain error.The United States Court of Appeals for the Tenth Circuit reviewed the case and found that the district court committed plain error by allowing the prosecutor to use Ward's post-arrest silence against him. The court held that this use of partial silence violated Ward's due process right to a fair trial, as established in Doyle v. Ohio and United States v. Canterbury. The court concluded that the error affected Ward's substantial rights and the fairness of the judicial proceedings. Consequently, the Tenth Circuit vacated Ward's convictions and remanded the case for further proceedings consistent with their opinion. View "United States v. Ward" on Justia Law

John Bragg was involved in a violent altercation with Lorenza Fletcher and Daquan Anderson in an apartment in Trenton, New Jersey. Bragg claimed he had an informal sublease and had been living in the apartment for a few weeks. During the fight, all three adults sustained serious injuries, and Bragg was arrested. He was later indicted on nineteen counts, including attempted murder and kidnapping. At trial, Bragg claimed self-defense, stating that Fletcher and Anderson initiated the fight, while they testified that Bragg was the aggressor.The trial court did not instruct the jury on the "castle doctrine," which states that a person does not have to retreat from their dwelling unless they were the initial aggressor. The jury found Bragg guilty of twelve counts, including attempted murder and kidnapping. The Appellate Division affirmed the convictions, concluding that the failure to instruct on the castle doctrine was not plain error and that the evidence did not support a finding of self-defense.The Supreme Court of New Jersey reviewed the case, focusing on whether the failure to instruct the jury on the castle doctrine constituted plain error. The Court found that the jury should have been instructed on the exception to the duty to retreat, as there was evidence suggesting the apartment could be considered Bragg's dwelling and conflicting testimony on who the initial aggressor was. The Court held that the failure to provide this instruction was capable of producing an unjust result and constituted plain error.The Supreme Court of New Jersey reversed the Appellate Division's judgment, vacated Bragg's convictions on counts involving self-defense, and remanded the case for further proceedings. The other counts of conviction, for which self-defense was not a possible defense, remained intact. View "State v. Bragg" on Justia Law

Patrick L. Beverly, II sold fentanyl pills to Matthew Bowen, who later died from consuming them. The coroner determined Bowen's death was a suicide. Beverly was charged with distributing less than four grams of fentanyl, with the distribution being the proximate cause of Bowen's death, which carries enhanced penalties under Colorado law.The El Paso County District Court denied the People's motion to exclude evidence of Bowen's suicidal intent, which Beverly intended to use as a defense. The People sought relief from the Supreme Court of Colorado, arguing that the trial court erred in its decision.The Supreme Court of Colorado held that evidence of a drug purchaser's suicidal intent might be relevant to determining whether the defendant's distribution of fentanyl was the proximate cause of the purchaser's death. The court reasoned that the term "proximate cause" includes the concept of an intervening cause, which can break the causal chain if the event is not reasonably foreseeable. The court concluded that a purchaser's suicide by intentional overdose could be an intervening cause, making the defendant's distribution not the proximate cause of death.The court also found that the trial court did not abuse its discretion in denying the People's motion to exclude evidence of Bowen's suicidal intent. The evidence was deemed relevant and not unduly prejudicial, as it could support Beverly's defense that Bowen's suicide was an intervening cause.The Supreme Court of Colorado discharged the order to show cause and affirmed the trial court's evidentiary ruling, allowing the evidence of Bowen's suicidal intent to be considered in determining proximate cause. View "People v. Beverly" on Justia Law

The defendant crashed his vehicle into a State police cruiser parked in the breakdown lane on Interstate Route 90, resulting in the death of a trooper. The defendant was convicted of involuntary manslaughter, misdemeanor motor vehicle homicide by means of negligent or reckless operation, operating a motor vehicle so as to endanger the lives or safety of the public, and operating an uninsured motor vehicle. The defendant appealed, arguing that the Legislature did not authorize multiple punishments for involuntary manslaughter, motor vehicle homicide, and operating to endanger arising from the same act. He also contended that the evidence was insufficient to sustain his involuntary manslaughter conviction and that his trial counsel was ineffective.The Superior Court judge denied the defendant's motion for a new trial. The Appeals Court reversed the convictions of motor vehicle homicide and operating to endanger, holding that the Legislature did not intend to impose multiple punishments based on the same act for those offenses where a defendant is also convicted of involuntary manslaughter. The Appeals Court upheld the involuntary manslaughter conviction and rejected the defendant's arguments regarding the insufficiency of evidence and ineffective assistance of counsel.The Supreme Judicial Court of Massachusetts granted further appellate review. The court reaffirmed its holding in Commonwealth v. Jones, which precludes multiple punishments for involuntary manslaughter, motor vehicle homicide, and operating to endanger based on the same act. The court affirmed the defendant's convictions of involuntary manslaughter and operating an uninsured motor vehicle but reversed the convictions of motor vehicle homicide and operating to endanger. The court also affirmed the denial of the defendant's motion for a new trial, finding no ineffective assistance of counsel. View "Commonwealth v. Njuguna" on Justia Law