Justia Criminal Law Opinion Summaries

The appellant was charged with multiple serious sexual offenses involving a minor, including first-degree rape, child sexual abuse by a person in a position of trust, and unlawful sexual contact. Prior to trial, his defense counsel raised concerns about his mental health and ability to participate meaningfully in his defense, noting that while the appellant understood the legal process and charges, he appeared unable or unwilling to engage in his own defense. The trial court ordered a psychiatric evaluation, which found the appellant incompetent to stand trial due to his refusal to participate. The parties subsequently agreed that he should undergo a competency restoration program.After completing the restoration program, a second psychiatric evaluation was conducted. This evaluation concluded that the appellant’s condition had improved, finding him able to communicate with counsel and participate in his defense. The Superior Court of the State of Delaware reviewed both evaluations and, after a teleconference with counsel, found the appellant competent to stand trial. The court scheduled trial, during which the appellant’s counsel did not again raise the competency issue. The appellant was convicted by a Superior Court jury of ten offenses and sentenced to 216 years of imprisonment.On appeal to the Supreme Court of the State of Delaware, the appellant argued that the trial court failed to make adequate factual findings in its competency ruling and that the record as a whole did not support the finding of competency. The Supreme Court reviewed the legal standard de novo and factual findings for support in the record, holding that the trial court relied on competent psychiatric evaluations and statements from counsel, satisfying its duty to make and briefly state factual findings. The Supreme Court found the record supported the determination of competency and affirmed the judgment of the Superior Court. View "Castro v. State" on Justia Law

Derrek Arrington was convicted by a jury of assaulting a Park Police officer with a deadly weapon—specifically, using a car to trap and drag the officer before shooting him in the face—and for being a felon in possession of a stolen firearm. He received a 240-month prison sentence for these offenses. After completing his federal sentence, Arrington remained incarcerated because his actions violated parole from a prior armed robbery conviction in D.C. Superior Court, resulting in an additional 11-year sentence.The United States District Court for the District of Columbia originally imposed the 240-month sentence. Years later, after Arrington had served his sentence for the assault and firearm convictions, a different district judge vacated the original sentence and resentenced Arrington, again imposing the 240-month term. The resentencing judge decided to depart upward from the Sentencing Guidelines range of 140-175 months, citing the extreme moral depravity of Arrington’s actions, including the severe and permanent injuries caused to the officer. The judge also referenced Arrington’s criminal history and questioned whether the Guidelines adequately accounted for the felon-in-possession charge.Arrington appealed to the United States Court of Appeals for the District of Columbia Circuit, arguing that the resentencing judge failed to consider his rehabilitation during his incarceration. The court found that, while the judge’s oral remarks could be interpreted as ambiguous, the record did not show that the judge ignored the rehabilitation evidence. The appellate court held that any error was not plain and that the upward variance was justified by the egregious nature of the conduct. The court also determined that any error regarding consideration of the firearm conviction was harmless. Therefore, the judgment of the district court was affirmed. View "USA v. Arrington" on Justia Law

A police officer responded to a complaint of littering at a McDonald’s parking lot in DeFuniak Springs, Florida, where he encountered John Thomas in a gray Acura matching the reported description. Thomas admitted to littering, exited his vehicle to pick up the trash, and then returned to the driver’s seat. When asked for identification, Thomas produced a Louisiana driver’s license that appeared false, given the age discrepancy. After confirming with the dispatcher that the license information did not match, the officer attempted to arrest Thomas, who resisted, pepper-sprayed the officer, and fled. Thomas abandoned his car nearby and was later apprehended. Police obtained a search warrant for the car, discovering methamphetamine, counterfeit bills, and numerous fraudulent identification documents.The United States District Court for the Northern District of Florida denied Thomas’s motion to suppress the evidence recovered from his car. Thomas argued the warrant was based on information obtained during an illegal stop, asserting that Florida law does not permit officers to detain someone for a noncriminal violation such as littering. The district court found the initial stop lawful, reasoning that the officer had authority to detain Thomas based on the littering complaint and to request identification. It further held that the subsequent arrest for providing false identification was supported by probable cause, validating the search warrant and denying suppression.Upon appeal, the United States Court of Appeals for the Eleventh Circuit affirmed the district court’s decision. The appellate court held that the initial encounter was consensual and did not implicate the Fourth Amendment, and that the officer had probable cause to arrest Thomas for possession of a fraudulent driver’s license under Florida law. Therefore, the evidence obtained from the car search was admissible, and Thomas’s conviction was affirmed. View "United States v. Thomas" on Justia Law

Anthony Seigler and his girlfriend, Katrina Fowles, were involved in two incidents in Lake County in early 2023. In the first, they called 911 reporting armed threats to their son and shots fired into their home; responders found Seigler had fired two shots through a bathroom wall while his son was present, but there was no evidence of an actual attack. Both appeared under the influence of drugs. In the second incident, Fowles’s mother reported a burglary at her home by Seigler and Fowles, and Seigler was found with stolen property. Seigler was charged in two separate cases: one for negligent discharge of a firearm, and another for burglary.The Lake County Superior Court repeatedly continued trial dates over several months for reasons including the need for witness availability, discovery issues, and defense counsel’s request for a mental health evaluation of Seigler due to concerns about his mental state and substance abuse. Despite counsel’s continued difficulty communicating with Seigler and attempts to secure a mental health evaluation, such evaluation was never performed. On the day of trial, defense counsel moved for a continuance and filed an application for mental health diversion. The trial court denied both, finding them untimely and inadequately noticed, and proceeded toward trial. Seigler then entered no contest pleas to both charges and was placed on probation.The California Court of Appeal, First Appellate District, Division Two, reviewed the case. It held that the trial court abused its discretion in denying the continuance, particularly given indications that Seigler’s mental health and substance abuse were significant factors and the statutory right to seek diversion before trial or plea. The Court of Appeal reversed the judgment and remanded, directing that Seigler be given a reasonable opportunity to apply for mental health diversion and, if granted and completed, for dismissal of charges; if not, the judgment would be reinstated. View "People v. Seigler" on Justia Law

A law enforcement officer applied for a search warrant based on information provided by a confidential informant, who had a record of reliability and admitted past drug use. The informant reported seeing a quantity of methamphetamine consistent with trafficking at the defendant’s residence within the previous seventy-two hours and stated the defendant kept a continuous supply of narcotics at her home and on her person. The affidavit described the informant’s familiarity with methamphetamine and recounted the informant’s prior accurate tips and participation in controlled drug buys. Based on this affidavit, a magistrate judge issued a search warrant. Officers executing the warrant found methamphetamine and paraphernalia, leading to the defendant's arrest and indictment for possession of methamphetamine and drug paraphernalia.The defendant moved to suppress the evidence in the Twelfth Judicial District Court, alleging that the affidavit failed to show an adequate basis for the informant’s knowledge because it lacked details on quantity, packaging, or observed sales. The district court agreed, referencing a nonprecedential Court of Appeals memorandum opinion, State v. Belknap, and found the affidavit insufficient. The State appealed. The New Mexico Court of Appeals reversed, concluding that the informant’s first-hand observation and demonstrated knowledge of methamphetamine established a sufficient basis for probable cause.The Supreme Court of the State of New Mexico reviewed the case to clarify the standard for establishing probable cause based on an informant’s tip under Article II, Section 10 of the state constitution and Rule 5-211(E) NMRA. The Court held that the affidavit provided a sufficient factual basis for probable cause because the confidential informant’s first-hand observations, combined with demonstrated credibility and knowledge, met the “basis of knowledge” prong. The Supreme Court affirmed the Court of Appeals’ decision to reverse the district court’s grant of the motion to suppress. View "State v. Perea" on Justia Law

The defendant was indicted in the district court on several felony and misdemeanor charges related to a civilian car chase involving gunfire. After indictment and entry of a scheduling order in district court, a police officer obtained two search warrants from the Bernalillo County Metropolitan Court to collect an oral swab and fingerprints from the defendant. Both supporting affidavits failed to disclose the defendant’s indictment and ongoing district court proceedings, and the second warrant was sought while the first was subject to a pending motion to quash in district court.The district court (Second Judicial District Court, Bernalillo County) quashed both warrants and suppressed the evidence, determining that the metro court lacked jurisdiction post-indictment and that the State’s actions violated the defendant’s due process rights. The district court further found that the affidavits were deceptive for omitting material facts about the pending proceedings and that the warrants conflicted with the court’s scheduling order. The suppression was without prejudice to the State seeking the same evidence via a district court motion. The State appealed, and the New Mexico Court of Appeals reversed, holding that the metro court retained authority to issue post-indictment warrants and that omissions in the affidavits did not invalidate the warrants.On certiorari review, the Supreme Court of the State of New Mexico held that metropolitan and magistrate courts retain concurrent authority to issue search warrants after formal criminal proceedings have begun in district court. However, the district court may quash such warrants under its inherent authority to manage its docket and proceedings. The Supreme Court found no abuse of discretion in the district court’s decision to quash the warrants and suppress the evidence, and reversed the Court of Appeals, affirming the district court’s ruling. View "State v. Chavez" on Justia Law

Detectives sought to arrest an individual based on an outstanding warrant and observed him near a corner store. When approached, he fled and discarded a loaded firearm into a bush. Upon apprehension, officers recovered the firearm and found five rocks of crack cocaine and $94 on his person. The individual had multiple prior felony convictions under Louisiana law, including attempted possession of a firearm by a convicted felon, aggravated flight from an officer, possession of heroin, possession of a firearm by a convicted felon, and aggravated battery. He pled guilty to knowingly possessing a firearm after being convicted of a felony.The United States District Court for the Eastern District of Louisiana sentenced him to 70 months of incarceration and three years of supervised release. The court applied a four-level sentencing enhancement under U.S.S.G. § 2K2.1(b)(6)(B), finding that he possessed the firearm in connection with another felony offense, specifically drug trafficking, based on the quantity of crack cocaine and circumstances of his arrest. The defendant objected, arguing there was insufficient evidence to support the enhancement, but the district court overruled the objection and adopted the Presentence Investigation Report.On appeal, the United States Court of Appeals for the Fifth Circuit reviewed his facial and as-applied constitutional challenges to 18 U.S.C. § 922(g)(1), as well as the application of the sentencing enhancement. The court held that existing precedent foreclosed his Second Amendment challenges to § 922(g)(1). Additionally, the Fifth Circuit concluded the district court did not clearly err in applying the four-level enhancement, determining that the record plausibly supported a finding that he possessed the firearm in connection with drug trafficking. Accordingly, the Fifth Circuit affirmed both the conviction and the sentence. View "USA v. McCree" on Justia Law

Late on January 10, 2022, Kansas City police officers stopped a pickup truck with a broken headlight and expired license plate. The driver, Alonzo Miller, was not the vehicle’s owner and could not provide proof of insurance. The officers recognized the area Miller had driven from as one known for criminal activity. During the stop, Miller exhibited nervous behavior. A computer check revealed Miller was on probation and parole for a violent felony involving a firearm. The officers, noting a significant age difference between Miller and his passenger and the late hour, suspected possible illicit activity. After Miller mentioned “something under there” when asked about illegal items and consented to a vehicle search, the officers asked him to step out. Miller behaved unusually, triggering further suspicion. As an officer attempted a frisk, Miller resisted, and a firearm discharged from his coat pocket. Miller was arrested and later indicted for being a felon in possession of a firearm.The United States District Court for the Western District of Missouri denied Miller’s motion to suppress evidence from the stop and search. The magistrate judge found the stop lawful, that Miller’s consent to search was voluntary, and that the officers had reasonable suspicion to extend the stop and frisk Miller based on the totality of the circumstances—including Miller’s criminal history, behavior, and responses during the encounter. The district court adopted these findings. Miller then entered a conditional guilty plea, preserving his right to appeal the suppression ruling.The United States Court of Appeals for the Eighth Circuit reviewed the denial of Miller’s suppression motion, applying de novo review to legal conclusions and clear error review to factual findings. The court held that, under the totality of the circumstances, the officers had reasonable suspicion to extend the stop, request consent to search the vehicle, and frisk Miller. The judgment of the district court was affirmed. View "United States v. Miller" on Justia Law

A law enforcement officer stopped a driver traveling on Interstate 10 in Pinal County, Arizona, suspecting a violation of Arizona Revised Statutes § 28-721(B), which requires drivers moving slower than the normal speed of traffic to use the right lane. The officer had observed the driver operating a 2007 Chevrolet Malibu in the middle lane, slowing below the speed limit, and being passed by another vehicle in the right lane. The officer also noted that the vehicle was newly registered in Nogales, Arizona, and had recently crossed the United States–Mexico border multiple times, fitting a profile for vehicles used in drug trafficking. During the stop, the officer requested a canine sniff, which led to the discovery of fifty-five pounds of marijuana in the trunk. The driver was arrested and charged with possession and transportation of marijuana for sale.Prior to trial in the Superior Court in Pinal County, the defendant moved to suppress the evidence, arguing that the officer lacked reasonable suspicion for the traffic stop. After an evidentiary hearing, the Superior Court denied the motion, finding the stop justified. The jury convicted the defendant, and the court imposed concurrent five-year prison sentences. On appeal, the Arizona Court of Appeals, Division Two, vacated the convictions, holding that the officer lacked reasonable suspicion under § 28-721(B), and concluding that the officer’s interpretation of the statute was overly broad.The Supreme Court of the State of Arizona reviewed the case. It held that the trial court did not abuse its discretion in denying the motion to suppress, because the officer had an objectively reasonable basis for suspecting a traffic violation under § 28-721(B), even if his interpretation of the statute could be debated. The Court clarified the standard for appellate review of video evidence, disapproving State v. Sweeney’s suggestion that appellate courts may independently review such evidence, and reaffirmed that factual findings should be reviewed for reasonable support in the record. The Supreme Court affirmed the trial court’s ruling, vacated the Court of Appeals’ opinion, and remanded for further proceedings. View "STATE OF ARIZONA v ALVAREZ-SOTO" on Justia Law

Two members of the Gypsy Joker Motorcycle Club were prosecuted for their roles in the kidnapping and murder of a former club member. The victim had previously been expelled from the club for theft, severely beaten, and later participated in a robbery at one defendant’s home. In retaliation, the defendants and other associates tracked down the victim, forcibly abducted him, and transported him to a remote location where he was tortured and killed. His body was subsequently found in a field. Both defendants held significant roles in the club, with one serving as chapter president and the other as a full member.Following initial arrests on state charges, federal prosecutors obtained an indictment in the United States District Court for the District of Oregon. The indictment charged both men with murder and kidnapping offenses under the Violent Crimes in Aid of Racketeering (VICAR) statute, kidnapping resulting in death, conspiracy to commit kidnapping resulting in death, and for one defendant, racketeering conspiracy under RICO. Some co-defendants pleaded guilty, but the two appellants proceeded to trial. A jury convicted both on all counts except the racketeering conspiracy charge for one defendant. The district court sentenced each to concurrent life sentences.On appeal, the United States Court of Appeals for the Ninth Circuit affirmed the convictions and sentences. The court held that a VICAR indictment is sufficient if it tracks the statutory language, even without enumerating elements of the predicate state offense. The panel found no error in various evidentiary rulings, including exclusions of certain character evidence and expert testimony, as well as the admission of evidence regarding the club’s nature and culture. The court also upheld the jury instructions on VICAR purpose and consideration of punishment, and rejected an Eighth Amendment challenge to mandatory life sentences, citing binding precedent. View "USA V. DENCKLAU" on Justia Law