Justia Criminal Law Opinion Summaries

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

In this case, the defendant was convicted of first-degree murder. The incident occurred on February 6, 2006, when the victim was shot multiple times in an apartment building. Several witnesses, including Corrin Cripps, Jeanette Martinez, and Michael Gomes, identified the defendant as the shooter. Cripps and Martinez were using cocaine at the time of the incident, and Gomes initially failed to identify the defendant in a photographic array. The defendant was later found in Puerto Rico, where he provided an alias to the police.The defendant's conviction was previously affirmed by the Supreme Judicial Court of Massachusetts, along with the denial of his first motion for a new trial. In November 2022, the defendant filed a second motion for a new trial, arguing that newly discovered evidence regarding the unreliability of eyewitness identifications entitled him to a new trial. This motion was denied by a Superior Court judge, and the defendant sought leave to appeal from a single justice of the Supreme Judicial Court, which was granted on the issue of the new eyewitness identification science.The Supreme Judicial Court of Massachusetts reviewed the case and affirmed the denial of the second motion for a new trial. The court agreed that the new research on eyewitness identification was indeed newly discovered evidence. However, it concluded that this new evidence would not have been a real factor in the jury's deliberations. The court noted that the new research primarily addressed the unreliability of stranger identifications, which was only relevant to one of the three eyewitnesses. Additionally, the jury had already been made aware of the potential issues with the eyewitness identifications through cross-examination. The court also pointed out that there was other evidence of the defendant's guilt, including his intent and consciousness of guilt demonstrated by his actions after the shooting. Therefore, the court held that the absence of the new evidence did not cast real doubt on the justice of the conviction. View "Commonwealth v. Mercado" on Justia Law

Tanaiveon Johnson was convicted of felony murder and other offenses related to a gang-related shootout in which his friend, Arraffi Williams, was killed. The incident occurred on September 13, 2017, and Johnson was indicted along with five others on September 19, 2018. Johnson faced multiple charges, including felony murder, aggravated assault, and firearm possession. During his trial in October 2021, Johnson was found guilty on all counts, and he was sentenced to life in prison plus a five-year probated sentence for one firearm count. Johnson's motion for a new trial was denied, leading to this appeal.The trial court allowed the State to reopen evidence during jury deliberations to introduce a jail call recording in which Johnson admitted to shooting back to protect the car during the incident. Johnson argued that this was an abuse of discretion, but the Supreme Court of Georgia found no abuse, noting that the State had discovered the call relatively quickly and that Johnson had taken steps to conceal it. The court also gave the defense time to prepare and present additional arguments.Johnson also claimed ineffective assistance of counsel, arguing that his trial counsel pressured him not to testify. The court found that counsel's advice was reasonable given Johnson's communication difficulties and that Johnson had not shown prejudice from not testifying. Johnson's proffered testimony was inconsistent and would not have likely changed the trial's outcome.Finally, Johnson argued that the trial court erred in its jury instructions regarding proximate cause. The Supreme Court of Georgia reviewed this claim for plain error and found that Johnson had not shown that the omission of a specific proximate cause instruction probably affected the trial's outcome. The court affirmed Johnson's convictions. View "JOHNSON v. THE STATE" on Justia Law

Antonio Wallace, convicted of felony murder in 2011, sought original autopsy photographs for his pending habeas case. He requested these photographs under the Open Records Act, but the District Attorney refused. Wallace then filed a motion in the superior court where he was convicted, arguing that his request fit within exceptions for "medical purposes" or "public interest" under OCGA § 45-16-27 (d).The trial court found Wallace's arguments unconvincing and denied his motion. Wallace was convicted in Ware County, and his conviction was affirmed by the Supreme Court of Georgia in 2020. In 2021, he filed a habeas corpus petition in Wheeler County. In 2024, he filed a motion for limited disclosure of original trial exhibits, specifically the autopsy photographs, to Dr. Jan Gorniak, citing the poor quality of the copies he had.The trial court held a hearing where Wallace's counsel argued that the photographs were necessary to establish ineffective assistance of counsel. The victim's sister opposed the disclosure. The trial court denied the motion, and Wallace appealed, raising the same arguments.The Supreme Court of Georgia reviewed the case and affirmed the trial court's decision. The court held that the disclosure of autopsy photographs was not for "medical purposes" as Wallace's intent was legal, not medical. Additionally, the court found that the disclosure was not "in the public interest" as the victim's family opposed it, and Wallace's arguments did not outweigh their privacy concerns. Thus, the District Attorney was not required to disclose the photographs. View "WALLACE v. THE STATE" on Justia Law

Deangelo Deshawn Morgan was convicted in 2023 for the fatal shooting of Sabron Mosby and the aggravated assault of Donoven King. The crimes occurred on October 15, 2018, and Morgan was indicted along with Cleavanta Jerrideau and Glenn Darius Smith. Morgan's trial was severed due to a conflict of interest with his counsel, and Jerrideau and Smith were acquitted in their joint trial. Morgan was later found guilty by a jury and sentenced to life in prison with the possibility of parole for malice murder and an additional twenty years for aggravated assault.Morgan's motion for a new trial was denied by the trial court after an evidentiary hearing. He appealed, arguing that the trial court abused its discretion by excluding evidence that the shooting was drug-related and implicating other potential suspects. He also claimed his trial counsel was ineffective for not properly arguing for the admission of this evidence and advising him not to testify.The Supreme Court of Georgia reviewed the case and found that the trial court did not abuse its discretion in excluding the evidence. The court held that the excluded evidence did not raise a reasonable inference of Morgan's innocence and was speculative. Additionally, the court found that Morgan's trial counsel's performance was not deficient, as the advice given was a strategic decision and not patently unreasonable.The Supreme Court of Georgia affirmed the trial court's decision, upholding Morgan's convictions and sentences. View "MORGAN v. THE STATE" on Justia Law