Justia Criminal Law Opinion Summaries

After being released from federal prison, an individual began a term of supervised release that required him to comply with several conditions, including avoiding new criminal conduct, truthfully answering his probation officer’s questions, and participating in mental health and substance abuse treatment programs. Within two months, the probation office alleged that he violated four conditions: failing to enroll in required treatment, lying to his probation officer about receiving services, missing a scheduled drug test, and committing a new state misdemeanor offense involving assault and stalking.The United States District Court for the Eastern District of Tennessee held a revocation hearing. The individual admitted to three of the violations—lying to his probation officer, failing to enroll in treatment, and missing the drug test—and contested only the allegation that he committed a new state crime. After hearing testimony and reviewing evidence, the district court found by a preponderance of the evidence that he had committed the misdemeanor, in addition to the three admitted violations. The court revoked his supervised release and imposed a 14-month prison sentence, at the top of the applicable guidelines range. The individual appealed, challenging only the finding that he committed the new state offense.The United States Court of Appeals for the Sixth Circuit reviewed the district court’s factual findings for clear error. The appellate court concluded that even if the district court erred in finding the new state offense, any such error was harmless because the three uncontested violations independently justified revocation and the sentence imposed. The court held that a single violation is sufficient to support revocation, and the guidelines range and sentence would have been the same regardless of the contested finding. Accordingly, the Sixth Circuit affirmed the district court’s judgment. View "United States v. Kidd" on Justia Law

The defendant was charged with one count of wire fraud after orchestrating a scheme in which he falsely presented himself as a wealthy and experienced investor to at least ten individuals, promising guaranteed returns on investments in the stock market and a cannabis store. Instead of investing the funds, he used the money for personal expenses. To maintain the appearance of legitimacy, he provided promissory notes and sent updates to victims about their supposed investments. When victims requested their money, he made excuses and, at times, threatened them.The United States District Court for the Western District of North Carolina accepted the defendant’s guilty plea to wire fraud. At sentencing, the court applied a two-level enhancement for abuse of trust under U.S.S.G. § 3B1.3, based on evidence that the defendant had assumed a position of trust with his victims by posing as a financial advisor and investor. The court also imposed two discretionary conditions of supervised release, requiring participation in substance abuse testing and treatment, and transitional support services. The defendant objected to the abuse-of-trust enhancement but did not object to the supervised release conditions.On appeal, the United States Court of Appeals for the Fourth Circuit reviewed the district court’s factual findings for clear error and its legal interpretations de novo. The Fourth Circuit held that the abuse-of-trust enhancement was properly applied because the defendant provided sufficient indicia to his victims that he held a position of private trust, even though he was an imposter. The court also held that the challenged supervised release conditions did not constitute an improper delegation of judicial authority to the Probation Officer, relying on its precedent. The judgment of the district court was affirmed. View "United States v. Brewer" on Justia Law

An attorney based in Oklahoma developed a business model to help out-of-state clients enter the state’s medical marijuana industry, which is governed by strict residency and disclosure requirements. He created a two-entity structure: one company, with nominal Oklahoma-resident owners, obtained the necessary state licenses, while a second company, owned and operated by out-of-state clients, ran the actual marijuana operations. The attorney did not disclose the true ownership structure to state authorities, and in some cases, marijuana was grown before the required state registrations were obtained. State authorities began investigating after noticing irregularities, such as multiple licenses listing the same address and repeated use of the same Oklahoma residents as owners, many of whom had little or no involvement in the businesses.Oklahoma state prosecutors charged the attorney with multiple felonies related to his business practices, including conspiracy and submitting false documents. While those charges were pending, a federal grand jury indicted him for drug conspiracy and maintaining drug-involved premises, based on the same conduct. In the United States District Court for the Western District of Oklahoma, the attorney moved to enjoin his federal prosecution, arguing that a congressional appropriations rider barred the Department of Justice from spending funds to prosecute individuals complying with state medical marijuana laws. The district court held an evidentiary hearing and denied the motion, finding that the attorney had not substantially complied with Oklahoma law, particularly due to nondisclosure of ownership interests and failure to obtain required registrations.On appeal, the United States Court of Appeals for the Tenth Circuit affirmed. The court held that the appropriations rider does bar the Department of Justice from spending funds to prosecute private individuals who comply with state medical marijuana laws. However, the court found that the attorney failed to substantially comply with Oklahoma’s requirements, so the rider did not protect him. The court concluded that the district court did not abuse its discretion in denying the injunction. View "United States v. Stacy" on Justia Law

The defendant, a former U.S. Coast Guard employee, was convicted by a jury of murdering two co-workers in Alaska. At the time of the government’s collection action, he held approximately $450,000 in a Thrift Savings Plan (TSP) account, a federal retirement savings plan. His wife had a statutory right to a joint and survivor annuity from the account, and federal law generally requires spousal consent for lump-sum withdrawals. Following his conviction, the government sought to collect the entire balance of his TSP account as restitution for the victims’ families.The United States District Court for the District of Alaska initially ordered restitution from the defendant’s retirement and disability income, including his TSP funds, but limited lump-sum withdrawals from the TSP without spousal consent, instead permitting monthly payments. On appeal, the United States Court of Appeals for the Ninth Circuit vacated the restitution order, holding that the district court could not use the All Writs Act to bypass statutory garnishment limits and remanded for a determination of whether the defendant’s benefit streams constituted “earnings” subject to a 25% garnishment cap under the Consumer Credit Protection Act.On remand, the district court issued amended restitution orders authorizing the government to collect the entire TSP account balance as a lump sum. The defendant appealed, arguing that statutory spousal protections limited the government to periodic garnishments. The United States Court of Appeals for the Ninth Circuit held that the government may only cash out a defendant’s TSP account to satisfy a restitution order under the Mandatory Victims Restitution Act if the plan’s terms would allow the defendant to do so at the time of the order. Because spousal consent was required and not obtained, the court vacated the restitution orders and remanded for further proceedings. View "United States v. Wells" on Justia Law

The case concerns an individual who was convicted by a jury in Rice County District Court of 29 criminal offenses, including racketeering, theft, receiving stolen property, and falsifying information. The convictions arose from a scheme involving the purchase of used vehicles, alteration of vehicle identification numbers, and the sale of stolen vehicles. The district court sentenced the individual to 117 months in prison and ordered restitution to 13 victims, totaling over $124,000. The defendant challenged all restitution awards, specifically disputing four of them on the grounds that they were not sufficiently connected to his convictions and that he lacked the ability to pay.After a hearing, the Rice County District Court vacated the four disputed restitution awards, finding that the State had not met its burden to prove the amount of loss by a preponderance of the evidence. The State appealed, and the Minnesota Court of Appeals reinstated the four awards. The appellate court interpreted Minnesota Statutes section 611A.045, subdivision 3(a), to require that a defendant’s affidavit must specifically indicate whether the challenge is to the amount of loss, the appropriateness of restitution for the item, or both. The court concluded that the defendant’s affidavit only challenged the connection between the restitution and the convictions, not the amount of loss, and thus the burden did not shift to the State.The Minnesota Supreme Court reviewed the case and held that, under section 611A.045, subdivision 3(a), an offender’s affidavit must specify for each item whether the challenge is to the amount of loss, the appropriateness of restitution, or both, before the burden shifts to the State. However, recognizing that prior case law may have caused confusion, the Supreme Court remanded the case to the district court to allow the parties to comply with this clarified standard. The decision of the Court of Appeals was affirmed in part, reversed in part, and the case was remanded. View "State v. Seeman" on Justia Law

Several individuals were convicted in separate proceedings in the Huntsville Municipal Court for violating city ordinances. Each person appealed his conviction to the Madison Circuit Court, seeking a trial de novo. Before those trials occurred, each defendant moved to dismiss the complaint, arguing that the municipal-court complaints failed to properly allege that the ordinances had been duly adopted and, in some cases, that the complaints referenced non-existent sections of the Alabama Code. All of these arguments were raised for the first time in the circuit court.The Madison Circuit Court granted the motions to dismiss in each case, sometimes stating that the complaints failed to confer jurisdiction. The City of Huntsville appealed these dismissals to the Alabama Court of Criminal Appeals, which consolidated the cases, reversed the circuit court’s judgments, and remanded for further proceedings. The defendants then sought review by the Supreme Court of Alabama, which consolidated the cases for decision.The Supreme Court of Alabama held that any defects in the municipal-court complaints did not deprive the circuit court of subject-matter jurisdiction, as that jurisdiction is conferred by statute. The Court further held that the defendants did not waive their challenges to the sufficiency of the complaints by failing to raise them in municipal court; such challenges could be raised during the pendency of the proceedings, including in the circuit court. However, the Court concluded that the municipal-court complaints met the requirements of the Alabama Rules of Criminal Procedure, specifically Rule 13.2(a), and did not need to include formal averments about the adoption of the ordinances. The Court affirmed the judgments of the Court of Criminal Appeals. View "Ex parte Sandifer" on Justia Law

A 16-year-old committed a violent home invasion, during which he sexually assaulted his former neighbor at knifepoint. He was convicted by a jury of multiple offenses, including rape, sodomy, oral copulation, robbery, burglary, and related enhancements. The original sentence was a combination of determinate and indeterminate terms, ultimately resulting in a total sentence of 44 years to life in prison, with parole eligibility at age 60 after a later modification.After serving more than 15 years, the defendant petitioned the Superior Court of Tulare County for recall and resentencing under California Penal Code section 1170(d), arguing that his sentence was the functional equivalent of life without parole (LWOP) and that excluding him from resentencing relief violated equal protection principles. The trial court denied the petition, finding that his sentence was not functionally equivalent to LWOP and that, under People v. Heard, he was not eligible for relief.On appeal, the California Court of Appeal, Fifth Appellate District, considered whether the functional equivalency analysis from People v. Contreras, which is rooted in Eighth Amendment jurisprudence, should apply to equal protection challenges under section 1170(d). The court declined to import the Eighth Amendment standard, instead applying a rational basis review as articulated in recent California Supreme Court decisions. The court held that the Legislature could rationally distinguish between juveniles sentenced to explicit LWOP and those, like the appellant, sentenced to lengthy terms with parole eligibility within their expected lifetimes. The court concluded that section 1170(d)’s limitation to LWOP sentences does not violate equal protection as applied to a 44-years-to-life sentence. The trial court’s denial of the petition was affirmed. View "People v. Baldwin" on Justia Law

Law enforcement officers obtained and executed a search warrant for “4279 Violet Circle, Lake Worth, FL,” believing it to be a single-family home occupied by the defendant. In reality, the property included a main residence and three efficiency apartments at the back, one of which was occupied by the defendant. These apartments had no separate addresses, mailboxes, or exterior markings. During the search, officers were directed by other residents to the defendant’s apartment, where they found firearms and drugs. The defendant was subsequently charged with multiple firearm and drug offenses.The defendant moved to suppress the evidence, arguing that the warrant was defective under the Fourth Amendment because it listed only the main address and not his specific apartment. The United States District Court for the Southern District of Florida held an evidentiary hearing, credited the testimony of the investigating officer, and found that the officers reasonably believed the property was a single-family home based on surveillance, property records, and the lack of distinguishing features for the apartments. The magistrate judge recommended denying the motion to suppress, and the district court adopted this recommendation. The defendant was found guilty after a stipulated-facts bench trial and sentenced to 144 months’ imprisonment.On appeal, the United States Court of Appeals for the Eleventh Circuit reviewed the denial of the motion to suppress. The court held that the search warrant satisfied the Fourth Amendment’s particularity requirement because the officers reasonably believed, after a diligent investigation, that the property was a single-family home. The court found no evidence that the officers knew or should have known about the separate apartments before executing the warrant. The court affirmed the denial of the motion to suppress and remanded for correction of a clerical error in the judgment. View "United States v. Schmitz" on Justia Law

In December 1990, Victor Tony Jones fatally stabbed his employers, Jacob and Matilda Nestor, during a robbery at their business in Miami-Dade County. Jones was found at the scene with the victims’ belongings and admitted to the killings at the hospital. He was convicted by a jury of two counts of first-degree murder and two counts of armed robbery. The trial court, following the jury’s recommendation, imposed death sentences for both murders, citing three aggravating factors and no mitigation. The Florida Supreme Court affirmed the convictions and sentences, and the United States Supreme Court denied certiorari in 1995.Over the following decades, Jones filed multiple unsuccessful motions for postconviction relief in the Circuit Court for Miami-Dade County and petitions for habeas corpus in state and federal courts. After Governor Ron DeSantis signed Jones’s death warrant in August 2025, Jones filed a sixth successive motion for postconviction relief, arguing newly discovered evidence of abuse at the Okeechobee School for Boys, racial disparities in Miami-Dade capital prosecutions, and due process violations in the warrant process. He also made post-warrant demands for public records related to the Okeechobee School. The circuit court summarily denied all claims and records requests.The Supreme Court of Florida reviewed the appeal and petition. It held that Jones’s claim of newly discovered evidence regarding abuse at the Okeechobee School was procedurally barred and meritless, as the alleged abuse was known to Jones long before trial and did not constitute evidence likely to yield a life sentence on retrial. The court also found no due process violation in the warrant process and no abuse of discretion in denying Jones’s public records requests. The habeas petition was denied as an improper attempt to relitigate previously decided issues. The court affirmed the circuit court’s orders, denied all relief, and refused to entertain any rehearing. View "Jones v. State" on Justia Law

The defendant and his then-wife, J, lived in Deschutes County, Oregon, and their marriage ended in divorce proceedings after J obtained a restraining order against the defendant. The criminal charges arose from two separate incidents: one in December 2016, when the defendant dragged J from their bedroom to the yard in freezing weather, and another in July 2017, when the defendant damaged J’s car with a power drill and made threatening statements. The December incident led to a second-degree kidnapping charge, while the July incident resulted in a menacing charge. The state also filed a motion in limine to limit certain evidence related to the divorce proceedings.The Deschutes County Circuit Court denied the defendant’s motions for judgment of acquittal on both charges and granted the state’s motion in limine in part, restricting argument about whether J gained a tactical advantage in the divorce from her allegations. The jury convicted the defendant of both kidnapping and menacing. On appeal, the Oregon Court of Appeals, sitting en banc, affirmed both convictions, though several judges dissented on aspects of the kidnapping and menacing rulings and the scope of the motion in limine.The Supreme Court of the State of Oregon reviewed the case. It held that the evidence was insufficient to support the kidnapping conviction because the movement of J did not constitute taking her “from one place to another” as required by ORS 163.225(1)(a); specifically, the movement did not increase her isolation or restrict her freedom of movement in the manner contemplated by the statute. The court reversed the kidnapping conviction. However, the court affirmed the menacing conviction, finding that the defendant’s words and conduct were sufficient for a rational factfinder to conclude he intended to place J in fear of imminent serious physical injury. The court also affirmed the trial court’s ruling on the motion in limine. The case was remanded for further proceedings consistent with these holdings. View "State v. Anderson" on Justia Law