Justia Criminal Law Opinion Summaries

The case concerns a defendant who was convicted by a jury of first-degree felony murder, attempted aggravated robbery, and conspiracy to commit aggravated robbery after a 2014 home invasion. The prosecution's case largely depended on the testimony of three of the defendant’s coworkers, who described his role in the crime and recounted events before and after the incident. Physical evidence, including firearms and shell casings, was introduced at trial, but no physical evidence directly tied the defendant to the crime.After his conviction and unsuccessful direct appeal, the defendant filed a postconviction discovery motion requesting information to support a claim that a crime scene investigator (CSI) who had testified at trial had committed perjury in another proceeding. He argued that this alleged perjury was material and that the State’s failure to disclose it violated his rights under Brady v. Maryland and Giglio v. United States. The Wyandotte District Court denied the motion, reasoning that the CSI’s testimony was not material to the conviction because the verdict rested on witness testimony, not physical evidence. A subsequent motion to alter or amend the judgment was also denied, with the court concluding the defendant could have presented his new arguments in his original motion.On appeal, the Supreme Court of the State of Kansas reviewed the district court’s decisions for abuse of discretion. The court held that the defendant failed to show the requested discovery could have affected the outcome of his trial, as required under the standard articulated in State v. Mundo-Parra. The court further found no abuse of discretion in the district court’s denial of the motion to alter or amend. The Supreme Court of Kansas affirmed the district court’s rulings. View "State v. Butler " on Justia Law

A 45-year-old man was convicted in Greene Circuit Court of first-degree rape of his 16-year-old niece, following an alleged incident at his fish-camp trailer. The prosecution presented no physical evidence, instead relying primarily on the niece’s testimony and that of other witnesses to whom she had spoken after the event. A key witness for the State was a supervisor from the Department of Human Resources (DHR), who investigated the allegations but did not interview the defendant. During trial, the DHR supervisor testified that, after her investigation, she found the allegations to be "indicated," meaning DHR found enough evidence to support them. The defendant objected to this testimony, arguing it inappropriately addressed the ultimate issue of guilt, but the trial court overruled the objection.After the jury convicted the defendant and he was sentenced, he moved for a judgment of acquittal or a new trial, raising the issue of the DHR supervisor’s testimony. The trial court denied the motion. The Alabama Court of Criminal Appeals affirmed the conviction, rejecting the argument that admission of the lay-witness testimony about the ultimate issue was improper.The Supreme Court of Alabama reviewed whether the Court of Criminal Appeals had erred in allowing lay-witness testimony that embraced the ultimate issue of guilt, in light of the precedent established in Naylor v. State, 108 So. 3d 1063 (Ala. Crim. App. 2012). The Supreme Court held that the trial court erred by admitting the DHR supervisor's lay opinion on the ultimate issue, that this error was preserved by objection, and that it was not harmless given the centrality of witness credibility and lack of physical evidence. The Supreme Court reversed the decision of the Court of Criminal Appeals and remanded the case for further proceedings. View "Ex parte Randolph" on Justia Law

In this case, the defendant was indicted in 2022 on two charges in the northern judicial district of Hillsborough County, New Hampshire. While serving a separate sentence in Pennsylvania in 2023, a detainer was lodged against him for these charges. On December 21, 2023, the defendant signed a request under the Interstate Agreement on Detainers (IAD) for final disposition of his pending New Hampshire charges. This request was sent by the Pennsylvania correctional facility to both the Hillsborough County Attorney’s Office and the Superior Court in Nashua (Hillsborough-South), rather than the Superior Court in Manchester (Hillsborough-North), where the charges were pending. The State delayed processing the paperwork, and the defendant was not brought to trial within the IAD’s 180-day period.The Superior Court (Messer, J.) initially granted the State’s motion for a 120-day extension but, upon reconsideration, found the State lacked good cause for the delay. The court determined that the defendant’s request had been adequately served and attributed the delay to the State’s inaction. As a result, the court dismissed the indictments with prejudice after concluding the State failed to bring the defendant to trial within the required period. The State’s subsequent motion to reconsider was denied as untimely.The Supreme Court of New Hampshire reviewed whether the 180-day period under the IAD began when the defendant’s request was delivered to Hillsborough-South instead of Hillsborough-North. The court held that under New Hampshire law, service on any superior court within the prosecuting officer’s jurisdiction is sufficient to trigger the IAD timeline. The court found that the defendant had complied with the IAD, and affirmed the dismissal of the indictments with prejudice. View "State v. Laforest" on Justia Law

A defendant was convicted following a jury trial after a fatal altercation with his father during a family gathering in Lincoln, Nebraska. The dispute began as a verbal argument, escalated when the father punched the defendant, and culminated when the defendant stabbed his father with a steak knife. The father died from a single stab wound to the chest. It was undisputed that the father initiated the physical confrontation and that the defendant was holding the knife when the fatal injury occurred. The defendant asserted multiple defenses at trial: self-defense, accident, lack of intent to kill, and sudden quarrel. Witnesses provided conflicting accounts about the defendant's statements and actions during the incident.In the District Court for Lancaster County, the defendant sought to introduce evidence of his father's history of violence and abuse, arguing it was relevant to his claim of self-defense. The court limited the admissible evidence to acts occurring within 10 years of the incident, citing remoteness and concerns of unfair prejudice. The court also refused to instruct the jury on unintentional manslaughter, finding that the evidence did not warrant such an instruction. After deliberation, the jury found the defendant guilty of first-degree murder and use of a deadly weapon to commit a felony, and he was sentenced to consecutive terms of imprisonment.Reviewing the case, the Nebraska Supreme Court held that the district court did not abuse its discretion in excluding evidence of older acts, as remoteness affects weight, not admissibility, and the court properly balanced probative value against prejudice. The refusal to instruct on unintentional manslaughter was affirmed because the evidence supported intentional killing. The court found sufficient evidence to sustain both convictions. Claims of ineffective assistance of counsel were rejected where the record was sufficient to do so; other claims were not addressed due to inadequate specificity or insufficient record. The judgment of the district court was affirmed. View "State v. Kruger" on Justia Law

A student at Dearborn School in Boston was found in possession of a nine millimeter Glock pistol with six rounds of ammunition during an administrative search. The juvenile, who had previously been subject to threats and assaults while commuting to school, did not have a license to carry the firearm but did possess a valid firearm identification card. After his arrest, the juvenile was readmitted to school, graduated, and subsequently completed occupational training and part-time employment.The Suffolk County Division of the Juvenile Court Department issued a delinquency complaint charging the juvenile with unlawful possession of a firearm, carrying a loaded firearm without a license, and unlawful possession of ammunition. During plea negotiations, the juvenile recommended a continuance without a finding (CWOF) on the firearm counts, while the Commonwealth sought commitment to the Department of Youth Services (DYS) until the juvenile’s nineteenth birthday. Both parties agreed to dismiss the ammunition charge. The judge allowed the CWOF on the firearm counts and dismissed the ammunition count, rejecting the Commonwealth’s argument that a CWOF was prohibited for the firearm charge. The judge subsequently denied the Commonwealth’s motion to revise or revoke the sentence, and the Commonwealth appealed.The Supreme Judicial Court of Massachusetts reviewed whether a Juvenile Court judge may impose a CWOF for a juvenile charged with carrying a firearm without a license under G. L. c. 269, § 10 (a). The court held that the statutes governing juvenile proceedings permit the judge to impose a CWOF for this offense, as the prohibition against CWOFs applies only to certain enumerated sex offenses and not to firearm offenses under § 10 (a). The order denying the Commonwealth’s motion to revise or revoke the sentence was affirmed. View "Commonwealth v. Q." on Justia Law

The defendant was convicted by a jury in 2002 on multiple federal drug and firearm charges, receiving a lengthy sentence. He unsuccessfully challenged his convictions and sentence through direct appeals and several motions for habeas relief under 28 U.S.C. § 2255, including claims of ineffective assistance, vindictive prosecution, and arguments based on later Supreme Court rulings. After a First Step Act sentence reduction in 2019, which resulted in an amended judgment and a reduced sentence, the defendant filed another pro se § 2255 motion in 2022, arguing that he was actually innocent of one of his firearm convictions because both firearm offenses occurred as part of the same drug conspiracy.The United States District Court for the District of South Carolina dismissed the defendant’s 2022 habeas motion on two alternative grounds: first, that it was an unauthorized “second or successive” motion because a First Step Act sentence reduction does not create a “new judgment” for purposes of AEDPA; and second, that it was untimely under the one-year limitations period, with no basis for equitable tolling. The district court found that even if the motion was not successive, it was still time-barred, and the merits of his claim did not justify tolling.The United States Court of Appeals for the Fourth Circuit reviewed only the question of whether a First Step Act sentence reduction results in a “new judgment” under AEDPA, having denied the defendant’s request to expand the appeal to include the timeliness issue. The Fourth Circuit held that, because the district court’s alternative ruling of untimeliness was not appealable and would remain unaffected regardless of the outcome on the “new judgment” issue, the court had no ability to redress the defendant’s injury. As a result, the appeal was dismissed as moot. View "United States v. Robinson" on Justia Law

The case concerns an individual who, after viewing pornographic videos online, believed that two people had violated federal obscenity laws. Despite reporting these suspicions to law enforcement without result, he decided to attempt a citizen’s arrest himself. He visited the couple’s home multiple times: the first time, disguised as a pizza delivery worker and equipped with restraints and weapons, he tried to detain one of them but was stopped and warned by police. On a later visit, he left documents at the door. On his final visit, after the couple had separated, he forcibly entered the home, leading to a physical altercation with one resident involving a firearm. Ultimately, he was arrested by police.In the Eighth Judicial District Court, Clark County, the defendant was charged with multiple offenses, including attempted second-degree kidnapping, second-degree kidnapping with the use of a deadly weapon, residential burglary while in the possession of a firearm, assault with a deadly weapon, battery with substantial bodily harm, and stalking. At trial, the district court excluded most evidence related to the alleged federal crimes of the victims, ruling that a citizen’s arrest defense was not available for federal felonies and that the evidence did not support such a defense. The court also declined to give a jury instruction on citizen’s arrest and did not sua sponte instruct the jury on lesser-included offenses.The Supreme Court of Nevada reviewed the appeal. It held that Nevada’s citizen’s arrest statute does not authorize private persons to arrest for federal felonies committed outside their presence; thus, the district court correctly excluded the evidence and denied the defense. The court also held that district courts are not required to give lesser-included-offense instructions sua sponte and overruled prior precedent requiring such instructions without a request. The remaining arguments were found meritless, and the convictions were affirmed. View "Ser v. State" on Justia Law

The defendant, Marcos Hernandez, has a documented history of violence against the mother of his child, Jessica Murillo, including multiple arrests and convictions for assault. His conduct escalated over several years, resulting in convictions for misdemeanor and felony assault of a family member under Texas law. In May 2023, Hernandez was found in possession of a short-barreled, unregistered 12-gauge shotgun while walking along a railroad track in El Paso, Texas. Subsequent investigation confirmed he had no firearms registered to his name. Hernandez was indicted for possession of a firearm by a convicted felon and possession of an unregistered firearm.The United States District Court for the Western District of Texas denied Hernandez’s motion to dismiss the indictment, in which he argued that both statutes violated the Second Amendment and, for one count, the Commerce Clause. Hernandez then pled guilty to both charges, admitting to his prior felony convictions and the facts surrounding the firearm. The district court sentenced him to concurrent terms of imprisonment and supervised release. Hernandez timely appealed.The United States Court of Appeals for the Fifth Circuit reviewed Hernandez’s constitutional challenges de novo. The court concluded that his facial Second Amendment and Commerce Clause challenges to 18 U.S.C. § 922(g)(1) are foreclosed by precedent. Regarding his as-applied Second Amendment challenges to both statutes, the Fifth Circuit held they fail because the Second Amendment does not protect possession of short-barreled shotguns and because Hernandez’s predicate offenses are crimes of violence. Under Fifth Circuit precedent, such convictions permit categorical disarmament. The court affirmed the district court’s judgment, upholding Hernandez’s convictions. View "United States v. Hernandez" on Justia Law

On February 26, 2022, the appellant and another individual arrived at a Conway, Arkansas house where several people had gathered. After an argument broke out between the appellant and a partygoer, the appellant made threats and left. He later returned with his accomplice, both armed, and a gunfight ensued outside the house. One person was fatally wounded after being shot multiple times. During the incident, a third party arrived with his child, and their vehicle was struck by gunfire, with evidence suggesting the child was endangered. Police recovered numerous shell casings at the scene matching the weapons used by both the appellant and his accomplice. The appellant was charged with capital murder, two counts of aggravated assault, and a firearm enhancement.The case was tried before the Faulkner County Circuit Court. A jury convicted the appellant on all counts, and the court imposed a life sentence without parole for capital murder, concurrent five-year sentences for aggravated assault, and a consecutive ten-year sentence for the firearm enhancement. The enhancement for committing the crimes in the presence of a child was dropped by the State. The appellant timely filed a notice of appeal, challenging six evidentiary rulings made during the trial.The Supreme Court of Arkansas reviewed the case. Applying an abuse-of-discretion standard, the court addressed each evidentiary challenge, including hearsay objections, expert testimony, and use of documents by a witness. The court found no reversible error, determining either that the disputed evidence was admissible under exceptions to hearsay or that the appellant failed to demonstrate prejudice. The court also concluded that the cumulative-error argument was not preserved for review. After conducting its required review for additional prejudicial error, the Supreme Court of Arkansas affirmed the convictions and sentences imposed by the circuit court. View "TATE v. STATE OF ARKANSAS" on Justia Law

James Ray Davis pleaded guilty in 2017 to several charges, including commercial and residential burglary. Later, while incarcerated, Davis filed a pro se petition for writ of habeas corpus in the county of his incarceration. In his petition, Davis asserted that his guilty plea was induced by prosecutor deception, ineffective assistance of counsel, and trial court misconduct. He also alleged constitutional and due process violations. The petition included affidavits that were difficult to interpret, and although Davis used a form referencing Arkansas Code Annotated section 16-112-201, he did not claim actual innocence or request scientific testing.The Jackson County Circuit Court treated Davis’s petition as seeking habeas relief under sections 16-112-101 to -123, since he neither stated a claim under section 16-112-201 nor filed the petition in the county of conviction as required for claims based on new scientific evidence. The circuit court denied Davis’s petition, concluding that he failed to state a cognizable action for the writ to issue. Specifically, the court found that Davis did not provide a sentencing order showing the alleged illegality of his sentence and did not demonstrate either facial invalidity of the judgment or lack of circuit court jurisdiction.The Supreme Court of Arkansas reviewed the case and applied the clearly erroneous standard to the circuit court’s ruling. The court held that Davis failed to establish a basis for habeas relief because he did not show that the judgment was invalid on its face or that the circuit court lacked jurisdiction. Without the sentencing order or proof of illegality, the Supreme Court of Arkansas affirmed the circuit court’s denial of Davis’s petition. View "DAVIS v. STATE OF ARKANSAS" on Justia Law