Justia Criminal Law Opinion Summaries

The defendant was stopped by police after officers saw that the registered owner of the vehicle had a suspended license. The stop occurred at night, and when the defendant rolled down his window, the officer detected the odor of alcohol. The officer observed that the defendant had glassy eyes, slurred speech, was sweating, avoided eye contact, and appeared confused about why he had been stopped. The defendant denied consuming alcohol and refused field sobriety tests. All interactions were captured on the officer’s body-worn camera. The defendant was arrested for driving under the influence, among other charges.At trial in the Circuit Court, the Commonwealth’s evidence consisted of the officer’s testimony and the body camera footage. The defendant moved to strike the evidence as insufficient, emphasizing the lack of chemical testing and absence of erratic driving. The trial court denied this motion and found the defendant guilty of driving under the influence, citing the totality of the observed circumstances. The defendant appealed, and the Court of Appeals of Virginia reversed the conviction. That court concluded that the officer’s testimony was not fully supported by the video evidence and found that alternative explanations for the defendant’s behavior, such as nervousness or tiredness, were reasonable hypotheses of innocence not excluded by the evidence.Upon review, the Supreme Court of Virginia found that the Court of Appeals had erred by reweighing the evidence and substituting its judgment for that of the trial court. The Supreme Court held that the combined circumstances—odor of alcohol, physical and behavioral observations, and immediacy of the stop—were sufficient to sustain the conviction for driving under the influence. The Court reversed the Court of Appeals and reinstated the trial court’s judgment. View "Commonwealth v. Richerson" on Justia Law

After the body of Susan Yates was found in an Akron cemetery in 2007, police arrested Phillip Jones, whose wife, Delores, later told a friend and police that her husband had confessed to the killing. Physical evidence, including DNA, and expert testimony linked Jones to the crime, and he was charged with aggravated murder, murder, and rape, with a death penalty specification. At trial, Jones admitted to causing Yates’s death but claimed it was accidental during consensual, rough sex. The prosecution presented evidence of violent sexual assault and similarities to a prior offense. Jones’s defense included his own testimony and mitigation evidence about his troubled background and mental health.Following conviction and a death sentence, Jones’s direct appeal to the Ohio Supreme Court raised constitutional and ineffective assistance of counsel claims. The court affirmed his conviction and sentence, and his application to reopen the appeal was denied. Post-conviction relief was also denied after an evidentiary hearing, with Ohio’s appellate courts concluding that any failures by counsel were not prejudicial or fell within reasonable professional judgment. Jones’s federal habeas petition before the U.S. District Court for the Northern District of Ohio was denied, though a certificate of appealability was granted on several claims.The United States Court of Appeals for the Sixth Circuit reviewed whether Jones’s Confrontation Clause rights were violated by admission of his wife’s out-of-court statements, and whether trial counsel provided ineffective assistance during both trial and penalty phases. The court held that the admission of some statements did not violate the Confrontation Clause, and that any error was harmless. It also found that counsel’s performance did not fall below constitutional standards, nor was there prejudice warranting relief. The Sixth Circuit affirmed the district court’s judgment, denying Jones’s habeas petition. View "Jones v. Shoop" on Justia Law

The defendant, who immigrated to the United States from Vietnam, operated a staffing agency that provided temporary laborers to various clients in Massachusetts. She managed most of the agency’s operations, including payroll, and worked closely with her daughter, who had accounting training. Between 2015 and 2019, the defendant withdrew over $3.7 million in cash from business accounts, frequently in increments just below the $10,000 federal reporting threshold, and used this cash to pay workers. Evidence at trial showed that the agency paid employees additional cash wages not reported to tax authorities, resulting in unpaid employment taxes and underreported payroll to the company’s workers’ compensation insurer, which led to lower insurance premiums.A federal grand jury in the District of Massachusetts indicted the defendant on four counts of failing to collect or pay employment taxes and one count of mail fraud. After a jury trial, she was convicted on all counts and sentenced to eighteen months’ imprisonment and two years of supervised release. She appealed, challenging the admission of evidence regarding the structuring of cash withdrawals, the district court’s refusal to give a jury instruction on implicit bias, the instructions related to tax obligations and good faith, and the sufficiency of the evidence supporting the mail fraud conviction.The United States Court of Appeals for the First Circuit reviewed the case and affirmed the convictions. The court held that evidence about the structuring of cash withdrawals was properly admitted as intrinsic to the charged offenses and relevant to intent. The refusal to instruct on implicit bias was not an error because the district court’s voir dire and instructions substantially covered the issue. The court found no reversible error in the jury instructions regarding tax law and good faith, and concluded that any error was harmless. Finally, the evidence of mail fraud was found sufficient, as it was reasonably foreseeable that the mail would be used in the insurance audit process. View "US v. Giang" on Justia Law

The defendant pleaded guilty to several firearm-related offenses, including unlawful assault weapon activity, possession of a short-barreled shotgun, possession of a silencer, unlawful large capacity magazine activity, and unlawful transfer of a handgun without using a licensed firearms dealer. He received an eight-year split sentence, with four years in county jail and four years under mandatory supervision. The defendant subsequently challenged the constitutionality of his convictions, arguing that each offense violated his rights under the Second Amendment.The Superior Court of San Luis Obispo County entered judgment against the defendant, which led to his appeal. In the appeal before the California Court of Appeal, Second Appellate District, Division Six, the defendant mounted facial constitutional challenges to the statutes under which he was convicted, asserting that these statutes impermissibly infringed his Second Amendment rights. He relied on recent precedents, including District of Columbia v. Heller, McDonald v. Chicago, and New York State Rifle & Pistol Association, Inc. v. Bruen, and attempted to introduce extra-record empirical evidence to support his claims.The California Court of Appeal, Second Appellate District, Division Six, reviewed the case de novo and rejected the defendant’s challenges. The court held that neither assault weapons nor short-barreled shotguns are arms protected by the Second Amendment under Heller and Miller, and that neither large capacity magazines nor silencers qualify as arms. The court further found that the requirement for firearm transfers to occur through licensed dealers does not meaningfully constrain the core right to keep and bear arms. The court affirmed the judgment, upholding all convictions and rejecting the defendant’s Second Amendment and preemption arguments. View "P. v. Hardy" on Justia Law

A driver was charged with misdemeanor vehicular manslaughter after running a red light and colliding with another vehicle, resulting in the death of the other driver. The accused had no prior criminal history and was not intoxicated at the time. Before trial, the accused sought misdemeanor diversion under Penal Code section 1001.95, submitting evidence of her positive character, community contributions, and the personal impact of the event. The prosecution opposed diversion, citing the gravity of the offense and the victim’s family’s opposition, while the accused argued that vehicular manslaughter was not among offenses excluded from diversion by statute.The Superior Court found the accused eligible for diversion but denied it, concluding she was not suitable due to the fatal consequences of her negligent conduct. After a request for reconsideration was also denied, the accused sought a writ of mandate from the Appellate Division of the Superior Court of San Diego County, which summarily denied relief without explanation.The California Court of Appeal, Fourth Appellate District, Division One, reviewed the case. The court held that the trial court abused its discretion by denying diversion based solely on facts inherent in the charged offense—namely, the death caused by negligent driving—without connecting those facts to the legislative purposes of the diversion statute, which include treatment, rehabilitation, and reducing collateral consequences of prosecution. The court further found that victim opposition, while important, cannot override legislative policy when considering diversion. The Court of Appeal concluded that Bobo lacked an adequate legal remedy other than writ relief and issued a writ of mandate directing the appellate division to vacate its prior denial and to require the trial court to reconsider the diversion request in accordance with the legal principles set out in the opinion. View "Bobo v. Appellate Division of Super. Ct." on Justia Law

A federal prisoner was sentenced in December 2020 and, due to pending charges in another jurisdiction, was held at a detention center in Rhode Island rather than being promptly transferred to his designated Bureau of Prisons (BOP) facility in South Carolina. During this period of post-sentencing detention, the prisoner claims to have participated in programs under the First Step Act (FSA), thereby accruing approximately 150 days of time credits, which could reduce his time in custody. However, the BOP did not recognize these credits because he had not undergone a formal risk and needs assessment—the BOP’s prerequisite for awarding such credits—until his eventual arrival at the designated facility in March 2022.After exhausting administrative remedies, the prisoner filed a pro se habeas petition in the United States District Court for the District of South Carolina, seeking recognition of his alleged FSA credits. The magistrate judge, without briefing or discovery, recommended dismissal. The district court adopted this recommendation, concluding that the BOP’s regulation reasonably required an initial assessment before credits could be earned, and applied Chevron deference to uphold the agency's interpretation. The district court also found no evidence the prisoner had “successfully participated” in qualifying programs before arrival at the BOP facility and dismissed the petition without prejudice, refusing to require a government response.On appeal, the United States Court of Appeals for the Fourth Circuit vacated the district court’s judgment and remanded. The Fourth Circuit held that the case was not moot, as the prisoner could still benefit from the FSA credits if his risk status changed or a warden approved his release. The court further held that, in light of the Supreme Court’s decision in Loper Bright Enterprises v. Raimondo, which overturned Chevron deference, the district court must independently determine whether the BOP’s interpretation of “successful participation” aligns with the best reading of the statute. View "Benson v. Warden FCI Edgefield" on Justia Law

A woman was discovered inside a Minot, North Dakota residence by one of its occupants, who awoke to find her, a stranger, in his bedroom. Upon confronting her, he noticed her wearing mismatched Adidas shoes, and she emptied her pockets to reveal prescription medications and car keys belonging to the residents. After the woman fled, the residents found their home in disarray and discovered $1,600 in rent money and several pieces of gold jewelry missing from a secret compartment in a drawer. Shortly after, police located a woman matching the description, wearing the same shoes, who admitted to taking a gold ring and the shoes. She was identified as Winona Keplin.Keplin was charged with burglary and theft of property in the District Court of Ward County, North Central Judicial District. Pursuant to a plea agreement, she pled guilty to burglary and the theft charge was dismissed. The State sought restitution for the missing cash and jewelry, and, after a hearing, the district court found the State’s witnesses credible and ordered Keplin to pay $5,882 in restitution, reflecting the value of the missing items.On appeal, the Supreme Court of the State of North Dakota reviewed whether the district court abused its discretion by awarding restitution for items not found on Keplin at her arrest. The Supreme Court applied a standard similar to abuse of discretion, affirming that findings of fact are not set aside unless clearly erroneous. The court distinguished this case from prior decisions where the causal connection between the defendant’s conduct and the loss was lacking. Here, the court found sufficient evidence of a direct connection between Keplin’s burglary and the victims’ losses. The Supreme Court of North Dakota affirmed the amended criminal judgment ordering restitution. View "State v. Keplin" on Justia Law

After police received information that Jeffrey Simpson had made threats to “shoot it out with police” and possessed a handgun, a SWAT team was deployed to arrest him at his workplace. When officers confronted Simpson, he failed to comply with commands, was struck by a less-lethal projectile, and responded by firing two or three rounds at the officers before his firearm jammed. Simpson attempted to clear the malfunction, reloaded his weapon, fired an additional round into the ground, and then surrendered. He was charged with multiple offenses related to both the shooting incident and prior events.Simpson pleaded guilty to several charges, including burglary, domestic violence, and drug possession, in Grand Forks County District Court. He proceeded to a jury trial on four counts of attempted murder and three counts of reckless endangerment. The jury found Simpson guilty on all remaining charges. After sentencing, a criminal judgment was entered against him.On appeal to the Supreme Court of the State of North Dakota, Simpson contended that the jury’s verdicts on the attempted murder counts were legally inconsistent and that there was insufficient evidence to support convictions on all four counts, given the limited number of shots fired. The Supreme Court held that the jury instructions correctly stated the law and that the definition of “substantial step” for attempted murder did not require separate shots for each named officer. The Court found no legal inconsistency in the verdicts and concluded that sufficient evidence supported the convictions under the deferential standard of review. The Court affirmed the criminal judgment but ordered the district court clerk to correct a clerical error regarding which counts Simpson pleaded guilty to and which were decided by jury verdict. View "State v. Simpson" on Justia Law

The defendant was charged with domestic violence, a class B misdemeanor, after an incident on September 18, 2024. During pretrial proceedings, she requested an evaluation of her fitness to proceed, which led to delays as she alternately authorized and withdrew consent for the release of her medical records. The situation was further complicated by her involvement in other pending criminal cases. After missing a hearing and further delays in obtaining the evaluation, the court issued a bench warrant to secure her presence for the evaluation, which ultimately found her fit to proceed. Following additional continuances and attorney substitutions, a jury found her guilty, and she was sentenced to 30 days in jail, with credit for time served.The District Court of Burleigh County, South Central Judicial District, managed the proceedings. At no point did the court find that the defendant was unfit to proceed; instead, the proceedings were delayed due to the complications surrounding the fitness evaluation and her cooperation. The defendant did not raise the issue of delay or seek dismissal under North Dakota statutes or procedural rules until her appeal.The Supreme Court of the State of North Dakota reviewed the case on appeal. The defendant argued that the case should have been dismissed because the period for suspending proceedings under N.D.C.C. § 12.1-04-08(2) or for undue delay under N.D.R.Crim.P. 48 had been exceeded. The Supreme Court held that the statutory dismissal deadline was never triggered because the district court had not found the defendant lacked fitness to proceed. The Court also found that Rule 48 did not provide a clear legal basis for dismissal under the circumstances and that there was no showing of prejudice. Thus, the Supreme Court affirmed the judgment. View "State v. Reynolds" on Justia Law

The case concerns an individual who sought to have the records of seven misdemeanor convictions sealed under Ohio law. These convictions, spanning from 2012 to 2016, included offenses such as unauthorized use of property, attempted theft, disorderly conduct, resisting arrest, and obstructing official business. The applicant, who was working as a licensed parenting counselor and pursuing further education in social work, argued that sealing her convictions was important for her professional advancement and background checks required for her career.The Hamilton County Municipal Court held a hearing on the applications and, despite the absence of opposition from the State of Ohio or the City of Cincinnati, denied the requests. The trial court found that the applicant had not demonstrated her rehabilitation sufficiently, noting her statement that “it’s just not me anymore” as the sole evidence offered. The court also concluded that the government’s interest in keeping the records public, given the nature and number of the offenses and the applicant’s intended field of social work, outweighed her interest in sealing them.On appeal, the First District Court of Appeals reversed the trial court’s decision regarding five of the convictions, holding that the lower court abused its discretion by considering the number and nature of the offenses and by weighing the governmental interest when the State had not objected. The Supreme Court of Ohio reviewed the case and held that the statute does not prevent a trial court from considering the number and nature of an applicant’s convictions when balancing interests, nor does the State’s failure to object prevent the court from considering the government’s interest. The Supreme Court of Ohio found that the court of appeals improperly substituted its judgment for that of the trial court, reversed its judgment in part, and reinstated the trial court’s denial of sealing for the five contested convictions. View "State v. J.B." on Justia Law