Justia Criminal Law Opinion Summaries

David Young was convicted by a jury in the Lewis Circuit Court of wanton murder, two counts of first-degree assault, and DUI with aggravating circumstances. The incident occurred on May 18, 2020, when Young, after consuming several beers, lost control of his vehicle in heavy rain, crossed the centerline, and collided head-on with a car driven by Jessica Tumlin, resulting in her death and serious injuries to two minor passengers, C.C. and B.M. Young's blood alcohol content was found to be 0.156 nearly three hours after the collision.The trial court denied Young's motion for a directed verdict on the murder charge, and he was convicted on all counts, receiving a sentence of twenty-five years' imprisonment. Young appealed, raising several issues, including the sufficiency of evidence for the murder charge, exclusion of a defense witness, limitations on discussing DUI per se law, sufficiency of evidence for serious physical injury to B.M., and a double jeopardy claim regarding the DUI and murder charges.The Supreme Court of Kentucky affirmed the murder and assault convictions but found a double jeopardy violation with the DUI conviction. The court held that the DUI conviction should be vacated because the elements required to prove DUI were subsumed within the wanton murder charge, thus violating double jeopardy principles. The case was remanded for entry of a new judgment consistent with this finding. View "Young v. Commonwealth" on Justia Law

Jamie Boggs was convicted of several sexual offenses, including sexual abuse, rape, and sodomy, all involving victims under twelve years of age. The abuse occurred between 2011 and 2016 while Boggs was in a relationship with Retta H., who had five children. The victims, Betty and Susan, testified to frequent and severe sexual abuse by Boggs. Retta corroborated some of the abuse and testified to physical abuse by Boggs. Boggs denied all allegations and was sentenced to forty years in prison.The Harlan Circuit Court handled the initial trial, where Boggs was convicted. He appealed, alleging multiple errors, including improper bolstering of the victims' testimony by a forensic interviewer, hearsay statements, improper admission of prior bad acts, and issues with jury instructions related to unanimity and double jeopardy. The trial court's jury instructions were not objected to by Boggs, leading to a waiver of those claims on appeal. The court also admitted evidence of prior bad acts to explain the victims' delayed reporting of the abuse.The Supreme Court of Kentucky reviewed the case. The court found that the forensic interviewer's testimony did constitute improper bolstering but deemed it harmless error. The court also found no palpable error in the admission of prior bad acts testimony or hearsay statements. The court concluded that the jury instructions issues were waived and not subject to review. Ultimately, the Supreme Court of Kentucky affirmed Boggs' conviction and sentence. View "Boggs v. Commonwealth" on Justia Law

Earl K. Johnson was convicted by a jury in Logan Circuit Court on four counts of complicity to traffic in methamphetamine, one count of engaging in organized crime, and one count of complicity to murder. The jury found him to be a persistent felony offender and recommended a life sentence, which the court imposed. Johnson appealed, arguing several trial errors, including a violation of his right to confrontation when a key witness, Pam Wetton, testified remotely due to health concerns.The Logan Circuit Court allowed Pam to testify via Zoom based on a letter from a physician’s assistant stating that travel would be difficult for her. Johnson objected, arguing that this violated his Sixth Amendment right to confrontation. The trial court overruled his objection, and Pam testified remotely. Johnson was convicted on all counts and sentenced to life in prison.The Supreme Court of Kentucky reviewed the case and found that allowing Pam to testify remotely violated Johnson’s right to confrontation. The court held that the Commonwealth failed to establish that remote testimony was necessary to further an important public policy and that the reliability of the testimony was assured. The court concluded that the error was not harmless beyond a reasonable doubt regarding the complicity to traffic convictions, as Pam’s testimony was crucial to those charges. Therefore, the court reversed Johnson’s convictions and sentences for complicity to traffic in methamphetamine.However, the court affirmed Johnson’s convictions and sentences for engaging in organized crime and complicity to murder. The court found that Pam’s testimony was harmless beyond a reasonable doubt for these charges due to the overwhelming evidence of Johnson’s guilt presented by other witnesses. The court also addressed and dismissed Johnson’s other claims of trial errors, including improper admission of other crimes and bad acts, hearsay statements, and the denial of a mistrial. View "Johnson v. Commonwealth" on Justia Law

In 2011, Carlos Heard was convicted of third-degree depraved-mind murder and second-degree intentional murder for shooting and killing his brother and another person during a struggle over a gun. The district court sentenced him to 313 months for second-degree intentional murder and 180 months for third-degree depraved-mind murder. Heard appealed to the Minnesota Court of Appeals, challenging the district court's decision to allow impeachment evidence at his trial. The court of appeals affirmed his convictions, and the Minnesota Supreme Court denied review. Heard subsequently filed four postconviction petitions, all of which were denied.In 2023, Heard filed a fifth postconviction petition, arguing that the Minnesota Supreme Court's decisions in State v. Coleman and State v. Noor announced new substantive rules regarding the mental-state element of third-degree depraved-mind murder, which should apply retroactively to his case. The district court denied his petition, and the court of appeals affirmed, holding that Coleman and Noor did not announce new rules but rather clarified existing law.The Minnesota Supreme Court reviewed the case and concluded that Coleman and Noor did announce new rules of substantive law that apply retroactively. Coleman clarified that the mental-state element for third-degree depraved-mind murder requires a showing of reckless disregard for human life, while Noor held that this mental state cannot exist when the defendant's actions are directed at a particular person. The court also held that a postconviction petitioner is not required to independently satisfy the requirements of State v. Knaffla if the petitioner establishes that a new interpretation of state law is retroactively applicable in the first postconviction petition filed after the new interpretation is announced.The Minnesota Supreme Court reversed the court of appeals' decision and remanded the case to the district court to consider the effect of Coleman and Noor on Heard's third-degree depraved-mind murder conviction. View "Heard v. State" on Justia Law

Patrick Scullark, Jr. was charged with possession of a controlled substance after police officers found methamphetamine in his fanny pack during a search incident to his arrest on unrelated charges. Scullark attempted to pass the fanny pack to another person before being handcuffed. He argued that the search violated his constitutional rights because he could no longer access the fanny pack at the time it was searched.The Iowa District Court for Black Hawk County denied Scullark’s motion to suppress the evidence, finding the search valid as a search incident to arrest. Scullark entered a conditional guilty plea, preserving his right to appeal the suppression ruling. The Iowa Court of Appeals reversed the district court’s decision, agreeing with Scullark that the search did not satisfy the search incident to arrest (SITA) exception because he could not access the fanny pack at the time it was searched.The Iowa Supreme Court reviewed the case and vacated the court of appeals decision, affirming the district court’s order. The court held that the search of the fanny pack was valid under both the United States Constitution and the Iowa Constitution. The court concluded that because the fanny pack was worn around Scullark’s waist at the time of his arrest, it was considered part of his person. Therefore, the search was justified as a search of his person incident to a lawful arrest, requiring no additional justification. The court emphasized that the SITA exception allows for a full search of the arrestee’s person and items immediately associated with the person. View "State v. Scullark" on Justia Law

Felipe N. Gonzalez Vazquez was involved in a standoff with law enforcement officers at a residence in Lincoln, Nebraska, on August 26, 2020. Vazquez, who had locked himself in a bedroom, fired multiple gunshots during the standoff, injuring two officers and fatally wounding one. Vazquez was charged with first degree murder and other related felonies. He was found guilty on all counts by a jury and sentenced to prison.In the district court, Vazquez filed motions in limine to exclude testimony about his gang affiliation and the specific nature of the arrest warrants, which were granted. During the trial, Vazquez made two motions for mistrial based on alleged violations of the court's order in limine, both of which were denied. The jury returned guilty verdicts on all charges, and Vazquez was sentenced to a term of not less than 70 years nor more than life for first degree murder, along with additional consecutive sentences for the other convictions.On appeal to the Nebraska Supreme Court, Vazquez argued that the district court erred in denying his motions for mistrial, admitting certain testimony, and accepting the guilty verdicts due to insufficient evidence. He also claimed cumulative error and ineffective assistance of trial counsel in 17 respects. The Nebraska Supreme Court found no abuse of discretion in the district court's rulings, determined that the evidence was sufficient to support the convictions, and concluded that Vazquez's claims of ineffective assistance of counsel either lacked merit, were not sufficiently raised, or could not be resolved on direct appeal. Consequently, the court affirmed Vazquez's convictions and sentences. View "State v. Vasquez" on Justia Law

Tony Clark was convicted of capital murder, attempted murder, and possession of a firearm by a previously convicted felon. His death sentence was affirmed by the Mississippi Supreme Court, and the United States Supreme Court denied his petition for writ of certiorari. Clark subsequently filed his first motion for post-conviction relief, claiming intellectual disability and ineffective assistance of counsel, among other issues.The Madison County Circuit Court initially reviewed the case, and the Mississippi Supreme Court affirmed Clark's convictions and sentence. Clark then sought post-conviction relief, which led to the current appeal.The Supreme Court of Mississippi reviewed Clark's motion for post-conviction relief. The court granted the motion in part, remanding the case to the Madison County Circuit Court for an Atkins hearing to determine if Clark is intellectually disabled, which would make him ineligible for execution under the Eighth Amendment. The court found that Clark presented sufficient evidence, including affidavits from medical professionals, to warrant a hearing on his intellectual disability claim. However, the court denied all other claims, including ineffective assistance of counsel related to mitigation evidence, Batson challenges, jury wheel issues, the avoiding arrest aggravator, jurors' racial bias, and jury instructions. The court also rejected Clark's cumulative error argument. The decision was to grant post-conviction relief in part and deny it in part. View "Clark v. State" on Justia Law

Kenleone Joe Nyandoro pleaded guilty to possessing a firearm while unlawfully using a controlled substance. He secured a plea deal allowing him to enter a rehabilitation program, with the charges to be dropped upon successful completion. However, Nyandoro was removed from the program after being arrested for fleeing from police. Consequently, the case proceeded to sentencing.The United States District Court for the Northern District of Texas denied Nyandoro's motion to withdraw his guilty plea, which he filed nearly ten months after entering it. He argued that the statute under which he pleaded guilty was unconstitutional. The district court found that the factors governing plea withdrawal did not favor Nyandoro and denied his motion. The court then sentenced him to 51 months’ imprisonment and three years of supervised release.On appeal, the United States Court of Appeals for the Fifth Circuit reviewed Nyandoro's arguments. He contended that the district court should have allowed him to withdraw his plea and that the court should not have accepted the plea initially. The Fifth Circuit found that the district court did not abuse its discretion in denying the motion to withdraw the plea, as the factors considered did not support Nyandoro's position. Additionally, the court held that Nyandoro's appeal waiver, which was part of his plea agreement, barred his challenge to the district court's acceptance of his guilty plea. The waiver was found to be knowing and voluntary, and it encompassed his constitutional claims.The Fifth Circuit affirmed the district court’s judgment, upholding Nyandoro's conviction and sentence. View "United States v. Nyandoro" on Justia Law

Gage Peters was convicted of criminal sexual abuse in Illinois in 2013, which required him to register as a sex offender for ten years. He moved to Indiana in 2016 and registered as required. In 2021, Peters vacationed in Florida, where he signed a form agreeing to lifetime registration as a sex offender. After returning to Illinois and then moving back to Indiana in 2022, the Hamilton County Sheriff’s Department informed him that he must register as a lifetime sex offender due to Florida's laws.The Hamilton Superior Court granted summary judgment in favor of the State, finding that Peters was required to register for life in Indiana because of his obligation in Florida. The Indiana Court of Appeals affirmed this decision, interpreting the relevant statute to require registration in Indiana for individuals with out-of-state registration obligations, regardless of the source of those obligations.The Indiana Supreme Court reviewed the case and held that the statute applies to individuals with out-of-state registration obligations, regardless of the source. However, the court found that Peters is not currently required to register in Florida because his registration obligations there lapsed when he moved out of the state. Consequently, the court concluded that Peters does not need to register as a sex offender in Indiana. The Indiana Supreme Court reversed the trial court's decision and remanded the case for entry of summary judgment in favor of Peters. View "Peters v. Quakenbush" on Justia Law

Rubin Delphonso Holman was convicted of robbery, assault with intent to rob (AWIR), and simple assault. The incident occurred on a Metro train where Holman and his friend, Mr. Black, engaged in inappropriate behavior towards Domini Dotson. After Dotson moved to another train car and reported the incident, Holman followed her, threatened her, and attempted to take her phone. When Dotson resisted, Holman assaulted her, and during the altercation, he took her phone. Holman later threw the phone onto the Metro tracks when approached by police.The Superior Court of the District of Columbia convicted Holman of the charges. Holman appealed, arguing that his convictions for simple assault and AWIR should merge with his robbery conviction under the Double Jeopardy Clause. He also contended that there was insufficient evidence to support his robbery conviction.The District of Columbia Court of Appeals reviewed the case. The court agreed with Holman that his convictions for simple assault and AWIR should merge with his robbery conviction, as robbery requires proof of assault, and thus, the lesser offenses are included within the greater offense of robbery. The court also found that there was sufficient evidence to support Holman’s robbery conviction, as a reasonable jury could infer that Holman intended to permanently deprive Dotson of her phone.The Court of Appeals reversed Holman’s convictions for simple assault and AWIR, affirmed his robbery conviction, and remanded the case for entry of a new judgment and commitment order reflecting only the robbery conviction. The court noted that resentencing was unnecessary as the trial court had imposed concurrent sentences. View "Holman v. United States" on Justia Law