Justia Criminal Law Opinion Summaries

The defendant was charged with multiple counts of predatory criminal sexual assault, aggravated criminal sexual assault, and aggravated criminal sexual abuse involving his younger half-sister, K.P., who was under the age of thirteen at the time of the alleged offenses. The key evidence presented was a video-recorded, victim-sensitive interview conducted with K.P. when she was nine years old, in which she described repeated sexual abuse by the defendant. Prior to trial, the State sought to admit this interview under section 115-10 of the Illinois Code of Criminal Procedure, and the Cook County circuit court held a reliability hearing, ultimately finding the statement sufficiently reliable for admission if K.P. testified.At trial, K.P. showed reluctance and limited recall when testifying, acknowledging her participation in the interview and identifying the defendant, but consistently stating she did not remember the events described or her prior statements. The defense emphasized that her statements were made following a brutal beating by another household member. Despite K.P.’s minimal substantive testimony regarding the abuse, the jury found the defendant guilty on several counts. The circuit court sentenced him to consecutive prison terms totaling 21 years and denied his motion for a new trial.The Appellate Court of Illinois, First District, affirmed the convictions, holding that K.P.’s in-court testimony satisfied the statutory and constitutional requirements for admitting her out-of-court statements. On further appeal, the Supreme Court of Illinois held that section 115-10(b)(2)(A) and the confrontation clauses of both the state and federal constitutions do not require a child witness to recall or accuse the defendant at trial for such statements to be admissible. The Court found that K.P. was available for cross-examination, and the admission of her prior statements did not violate the defendant’s confrontation rights. The judgments of the circuit and appellate courts were affirmed. View "People v. Butler" on Justia Law

A Kendall County sheriff’s deputy responded to a domestic battery call at the home of Isaiah Williams and his girlfriend. During the deputy’s investigation and Williams’s subsequent arrest and transport, Williams made several threatening statements toward the deputy, some of which included specific threats to harm and kill the officer. These statements were captured on video and were later admitted as evidence at trial. Williams was charged with aggravated domestic battery and threatening a public official under Illinois law, which requires that threats to a sworn law enforcement officer contain specific facts indicative of a unique threat, not just a generalized threat of harm.The case was first tried in the Circuit Court of Kendall County, where Williams’s counsel did not object to the jury instructions provided, which included Illinois Pattern Jury Instructions, Criminal Nos. 11.49 and 11.50. The jury found Williams not guilty of aggravated domestic battery but guilty of threatening a public official, and he was sentenced to probation. On appeal to the Appellate Court of Illinois, Second District, Williams argued that the jury instructions were conflicting and potentially misleading regarding the “unique threat” element. The appellate court rejected this argument, finding the instructions complementary—one providing a general definition, and the other specifying the required propositions for conviction, including the unique threat requirement—and affirmed Williams’s conviction.The Supreme Court of the State of Illinois reviewed the case. It held that the trial court did not err in providing both instructions, as they were not inconsistent and, when read together, accurately conveyed the law and required elements to the jury. The court further held there was no plain error nor ineffective assistance of counsel related to the instructions. The Supreme Court affirmed the judgments of both the appellate and circuit courts. View "People v. Williams" on Justia Law

The defendant was charged with aggravated battery in a public place following an incident at a bar. Initially charged with misdemeanor battery, the State later enhanced the charge to two felony counts. The defendant participated in pretrial hearings, often via Zoom, and was twice expressly admonished by the trial court that his failure to appear at future court dates, including trial, could result in trial and sentencing in absentia. Despite these warnings, the defendant did not appear on the scheduled trial date. The trial proceeded in his absence, and a jury found him guilty. He was subsequently sentenced in absentia and later taken into custody.After conviction, the defendant appealed, arguing the trial court had erred by proceeding with the trial in absentia without strictly complying with section 113-4(e) of the Illinois Code of Criminal Procedure. Specifically, he pointed out that the trial court did not inform him that his absence would waive his right to confront witnesses. The Appellate Court of Illinois, Second District, agreed, holding that the admonishments were insufficient because both warnings—the possibility of a trial in absentia and the waiver of the right to confront witnesses—are required. The appellate court reversed the conviction and remanded for a new trial.The Supreme Court of the State of Illinois reviewed the case and addressed whether the trial court’s admonishments substantially complied with section 113-4(e). The court held that substantial compliance does not demand a verbatim recitation of the statute, but rather that the defendant be made aware that the trial could proceed in his absence. The court concluded that advising the defendant of the risk of a trial in absentia was sufficient to meet the statute’s essence, even without explicitly stating the waiver of confrontation rights. The Supreme Court reversed the appellate court’s decision and affirmed the conviction. View "People v. Hietschold" on Justia Law

The defendant was charged with preventing arrest and domestic violence following an incident at his mother’s residence in Minot, North Dakota. The alleged facts included a confrontation between the defendant and his sister, during which she claimed the defendant pushed her, causing her to fall and sustain injuries. Police responded to the scene, and when attempting to arrest the defendant, he physically resisted, repeatedly stating he was “not going to jail.” Officers used force to restrain and handcuff him, and body camera footage was entered into evidence.The case was heard in the District Court of Ward County, North Central Judicial District. At trial, testimony was provided by the victim, two police officers, and the defendant. The court also reviewed photographic and video evidence. The defendant made motions for acquittal at the close of the State’s case and at the end of all evidence, both of which were denied. The District Court found the defendant guilty of both charges, sentencing him to 360 days’ imprisonment with most suspended for supervised probation on the preventing arrest conviction, and a concurrent 30-day sentence on the domestic violence conviction.On appeal to the Supreme Court of North Dakota, the defendant argued that the evidence was insufficient to support his convictions, claiming he was not informed of his arrest before being restrained and that he acted in self-defense with no intent to cause injury. The Supreme Court held that sufficient evidence supported both convictions. The Court found that the officers were justified in not informing the defendant of his arrest prior to his resistance, and that the defendant’s actions toward his sister constituted willful, or at least reckless, conduct resulting in bodily injury. The criminal judgment was affirmed. View "State v. Gores" on Justia Law

On November 4, 2024, an individual went to his stepchild’s elementary school to speak with the principal about the child’s recent suspension from bus privileges. During and after this meeting, his behavior—raising his voice, pushing a garbage can into a door, forcefully exiting the building, yelling obscenities, and making obscene gestures in the presence of children—alarmed the principal, a school counselor, and a paraprofessional. Each testified that his actions caused them alarm. He was later charged with disorderly conduct under North Dakota law.The case proceeded to a bench trial in the District Court of Richland County, Southeast Judicial District. The defendant waived his right to a jury trial. The district court found, based on testimony and the totality of the conduct, that the defendant’s actions—including using obscene language, physical agitation, and reckless driving in the school parking lot—constituted tumultuous behavior that reasonably alarmed those present. The court found the statutory elements of disorderly conduct were proven beyond a reasonable doubt and entered a criminal judgment of conviction. The defendant appealed.The Supreme Court of North Dakota reviewed the conviction. The defendant argued that his conduct was constitutionally protected as an exercise of parental rights and that the evidence was insufficient. The Supreme Court held that because the defendant did not raise constitutional claims at trial or argue obvious error on appeal, those arguments would not be addressed. Applying the standard of viewing evidence in the light most favorable to the verdict, the court found that there was sufficient evidence that the defendant acted with at least reckless disregard as to whether his behavior would alarm others and that his conduct was tumultuous. The Supreme Court of North Dakota affirmed the conviction for disorderly conduct. View "State v. Vetter" on Justia Law

The defendant was charged with several offenses after a violent confrontation with a 20-year-old escort in his Queens home, leading to a police investigation that uncovered weapons, ammunition, forgery devices, and other items on the premises. During the jury trial, an alternate juror replaced a dismissed juror, leaving no further alternates. After the jury began deliberations, the foreperson reported an encounter outside his home with a man acting "on behalf of" the defendant, who provided court documents and claimed the defendant’s innocence. The foreperson, shaken by the incident, felt unable to remain impartial and was discharged from the jury.The Supreme Court, Queens County, held a hearing and found by clear and convincing evidence that the defendant orchestrated the confrontation with the foreperson, including feigning illness to leave court early. The court determined that this egregious misconduct was intended to improperly influence the jury. With no alternates available, the court, relying on forfeiture principles from prior cases, concluded the defendant forfeited his constitutional right to a jury of 12, and proceeded with 11 jurors. The 11-person jury found the defendant guilty on some counts and acquitted him on others.The Appellate Division affirmed the conviction, holding that the defendant’s "egregious" misconduct warranted forfeiture of the right to a 12-person jury. A dissenting Justice argued that such forfeiture should only occur in extreme circumstances, analogizing the right to a jury of 12 to the right to counsel. Upon review, the New York Court of Appeals held that a defendant who engages in egregious conduct affecting a sworn juror after deliberations begin, resulting in discharge and no alternates remaining, forfeits the right to a jury of 12. The court affirmed the trial court’s exercise of discretion in proceeding to verdict with 11 jurors. View "People v Sargeant" on Justia Law

In two separate incidents, young children under the care of their fathers began exhibiting symptoms commonly known as the “triad” associated with Shaken Baby Syndrome/Abusive Head Trauma (SBS/AHT): subdural hematoma, retinal hemorrhages, and encephalopathy. In each case, a child abuse pediatrician diagnosed the children with SBS/AHT. Both fathers were subsequently charged with aggravated assault and child endangerment based on these findings. The State intended to call the diagnosing physician as an expert witness to testify that, to a reasonable degree of medical certainty, the only plausible explanation for the children’s symptoms was shaking by the caregiver. The defense in both cases moved to exclude this testimony, challenging the scientific reliability of the SBS/AHT theory, specifically the claim that shaking alone, without any impact, can cause the observed injuries.In the Superior Court, following a Frye hearing in one case, the trial judge excluded the SBS/AHT expert testimony, concluding that the scientific basis for the diagnosis was not sufficiently reliable under the Frye standard, particularly given the lack of acceptance in the biomechanical community. The other trial court adopted this determination for the related case. The Appellate Division consolidated the appeals and affirmed both trial courts, holding that SBS/AHT testimony based solely on shaking without impact did not meet the required standard of reliability for expert evidence.The Supreme Court of New Jersey reviewed the cases. It held that the State failed to establish that expert testimony diagnosing SBS/AHT based on shaking without impact is generally accepted in both the medical/pediatric and biomechanical engineering communities, as required under Frye. The Court affirmed the exclusion of the expert testimony and upheld the dismissal of the indictment in one case due to insufficient causation evidence without the barred testimony. View "State v. Nieves" on Justia Law

Late one night in January 2019, three men—Sean Shuler, Javon Abney, and Tyrik Hagood—were shot and killed on a street in Southeast Washington, D.C. Rakeem Willis and Jonathan Winston were charged with three counts of first-degree (premeditated) murder in connection with these deaths. Evidence at trial included eyewitness accounts, forensic findings, and extensive cell phone records, including historical cell site location information (CSLI) used to trace phone movements. The government presented FBI Special Agent Billy Shaw as an expert to interpret the CSLI data, linking Willis’s phones to the vicinity of the crime and subsequent locations.Prior to trial, Winston moved to exclude the CSLI expert’s report and testimony, arguing the government’s notice was insufficient under Superior Court Rule of Criminal Procedure 16 and that the methodology lacked reliability as required by Motorola Inc. v. Murray and Federal Rule of Evidence 702. The motions court admitted the expert testimony over objections, relying on prior experience and cross-examination as safeguards, and declined to hold a Daubert hearing. The trial court later granted Winston’s motion for judgment of acquittal, but Willis was convicted by a jury of all three murder counts and sentenced to 120 years in prison.On appeal, the District of Columbia Court of Appeals found that the motions court failed to properly exercise its gatekeeping role under Rule 702 and Motorola by not sufficiently evaluating whether the expert had reliably applied CSLI methodology to the facts. The appellate court held this error was not harmless, given the centrality of the expert testimony to the government’s case. It therefore reversed Willis’s first-degree murder convictions and remanded for further proceedings. View "Willis v. United States" on Justia Law

A man drove his semi-truck into the shipping yard of a bedding company in Navarro County, Texas, and attempted to attach his truck to a trailer loaded with mattresses and box springs. The trailer was scheduled for authorized pickup by a specific carrier, but the man was neither driving an authorized vehicle nor had he followed the required check-in procedures. An employee grew suspicious, documented the incident, and involved supervisors and police. The man claimed he believed he was lawfully dispatched to pick up the load, but the person he named as his dispatcher denied involvement. The State charged him with cargo theft, alleging that he intentionally conducted an activity—connecting his truck to the trailer—in which he possessed stolen cargo.A jury convicted the man of cargo theft under Texas Penal Code § 31.18(b)(1), and the trial court sentenced him to thirty-seven years’ imprisonment. On appeal, the Tenth Court of Appeals affirmed, finding that the evidence showed he possessed the cargo and that his actions met the statutory definition of conducting an activity involving stolen cargo. The Texas Court of Criminal Appeals initially agreed on some points and remanded for clarification on whether the defendant’s conduct constituted the requisite “activity” under the statute. On remand, the court of appeals again affirmed the conviction, concluding that backing under the trailer and trying to connect brake lines constituted activity in which he possessed stolen cargo.The Texas Court of Criminal Appeals reviewed the case and held that the cargo theft statute is not materially different from the organized retail theft statute and requires proof of conduct distinct from the acts inherent in stealing. Because the only conduct proved was inherent in the theft itself, the evidence was insufficient to support a conviction for cargo theft. The judgment of the court of appeals was reversed, and the case was remanded to consider possible lesser included offenses. View "JOE v. STATE OF TEXAS" on Justia Law

The defendant was indicted for aggravated assault, a second-degree felony, and tried in Harris County district court in January 2023. During the trial, the court required all participants, including witnesses, to wear surgical masks at all times, except when necessary for in-court identifications. The defendant’s counsel objected to the mask mandate on Sixth Amendment grounds, arguing that masking hindered the jury’s ability to assess witness credibility by observing facial expressions. The objection was overruled, and the two key witnesses to the assault testified while masked. The defendant was subsequently convicted.On appeal, the Fourteenth Court of Appeals reversed and remanded the conviction, finding that the mask mandate violated the defendant’s constitutional right to confrontation. The appellate court emphasized that concealing facial features impairs the fact-finder’s ability to evaluate witness demeanor, citing Romero v. State and other precedents. When considering whether this constitutional error was harmless, the court relied on a procedural rule that places the burden on the State to show harmlessness beyond a reasonable doubt. Because the State did not substantively address the issue of harm in its brief, the court presumed harm and reversed the judgment.The Court of Criminal Appeals of Texas reviewed the case. It agreed that the trial court’s mandatory masking policy violated the defendant’s Sixth Amendment right to confrontation, as it did not make any case-specific findings of necessity or individualized determinations for masking. However, the Court held that the appellate court erred by applying a rule of default and presuming harm solely because the State did not brief the issue. The Court clarified that appellate courts have an independent duty to assess harmlessness under Chapman v. California and Rule 44.2(a), regardless of the State’s briefing. The judgment was reversed and remanded to the Fourteenth Court of Appeals to determine whether the error was harmless beyond a reasonable doubt. View "SMITH v. STATE OF TEXAS" on Justia Law