Justia Criminal Law Opinion Summaries

Mika Lee Thille was convicted of reckless second-degree murder after an incident at Justin Willingham's house. Thille, along with three companions, went to the house to confront his brother Max, who was using heroin there and had allegedly stolen handbags from one of the companions, Valerie Vogel. Upon arrival, a confrontation ensued between Thille and Willingham, during which Willingham was shot and killed. Witnesses provided conflicting accounts of the events, with some claiming Thille fired the shots and others suggesting Willingham had a gun and fired first.The Saline District Court charged Thille with first-degree premeditated and felony murder, among other charges. The jury convicted him of reckless second-degree murder but acquitted him of the other charges. Thille appealed, arguing that the district court erred by not providing jury instructions for voluntary manslaughter under sudden quarrel and imperfect self-defense theories, as well as for involuntary manslaughter.The Kansas Court of Appeals upheld the district court's decision, finding that the voluntary manslaughter instructions were not factually appropriate. The court reasoned that there was no evidence of sufficient provocation or an honest belief that lethal force was necessary. The panel also held that while an involuntary manslaughter instruction was factually appropriate, the district court's failure to give it was harmless.The Kansas Supreme Court reviewed the case and affirmed the lower courts' decisions. The court agreed that the voluntary manslaughter instructions were not factually appropriate due to a lack of sufficient provocation and no evidence of an honest belief in the necessity of lethal force. The court also found that the failure to instruct on involuntary manslaughter was not clear error, as the evidence strongly supported the jury's conclusion of reckless second-degree murder. View "State v. Thille " on Justia Law

Byron Williams pled guilty to three counts of being a felon in possession of a firearm, violating 18 U.S.C. §§ 922(g)(1) and 924(a)(2). He was found with handguns on three separate occasions between January 2020 and March 2021, despite being prohibited from possessing firearms due to prior felony convictions. The incidents involved a traffic stop, an altercation reported by his ex-girlfriend, and a high-speed chase following a disturbance.The United States District Court for the Western District of Missouri sentenced Williams to 240 months’ imprisonment. Williams appealed, arguing procedural error and the substantive unreasonableness of his sentence. He contended that the district court improperly limited his argument for a downward variance at sentencing and failed to adequately consider his intellectual disabilities.The United States Court of Appeals for the Eighth Circuit reviewed the case. The court found that while the district court initially interrupted Williams’s counsel, it ultimately allowed her to present arguments regarding Williams’s intellectual disabilities and other mitigating factors. The appellate court determined that the district court did not abuse its discretion in limiting arguments related to Williams’s competency, which had already been decided.Regarding the substantive reasonableness of the sentence, the Eighth Circuit held that the district court did not abuse its discretion. The court justified the upward variance from the Guidelines range based on Williams’s criminal history, high risk of recidivism, and the danger he posed to the community. The appellate court concluded that the district court appropriately weighed the relevant factors and affirmed the 240-month sentence.The Eighth Circuit affirmed the judgment of the district court, finding no procedural error or substantive unreasonableness in the sentence imposed on Williams. View "United States v. Williams" on Justia Law

Marqus Patton was convicted by a Nebraska jury of first-degree murder and using a deadly weapon during a robbery following the attempted robbery and fatal shooting of Kristopher Winters. Patton filed a habeas corpus petition under 28 U.S.C. § 2254(d), alleging that his due process rights were violated because the State failed to disclose tacit plea agreements with two witnesses, Emily Gusman and Drake Northrop, who testified against him at trial.The United States District Court for the District of Nebraska denied Patton’s habeas petition but granted a certificate of appealability. The district court was skeptical about the absence of agreements but concluded that the Nebraska Supreme Court’s finding that no tacit plea agreements existed was not unreasonable. The district court also found that any undisclosed agreements would not have been material to the trial's outcome due to the extensive cross-examination of the witnesses.The United States Court of Appeals for the Eighth Circuit reviewed the case. The court noted that the Nebraska Supreme Court had determined there were no tacit plea agreements, and this conclusion was not unreasonable based on the evidence. The court emphasized that under the Antiterrorism and Effective Death Penalty Act of 1996 (AEDPA), a state court’s factual determinations are presumed correct unless rebutted by clear and convincing evidence. The Eighth Circuit found that the evidence supported either conclusion regarding the existence of tacit plea agreements and that the state court’s determination was reasonable.The Eighth Circuit affirmed the district court’s denial of Patton’s habeas petition, concluding that the state court’s adjudication did not involve an unreasonable determination of the facts. View "Patton v. Boyd" on Justia Law

Law enforcement traced the online distribution of child pornography to the defendant after receiving a tip from the National Center for Missing and Exploited Children. A search of his home led to the discovery of numerous video files containing child pornography, and the defendant admitted to both possessing and distributing such material for profit. He was charged with 20 counts of Sexual Exploitation of a Child, with some counts relating to files uploaded on a specific date and others to files found on his computer during the search.The defendant pled guilty to all charges in the District Court of Big Horn County. He was sentenced to concurrent prison terms for counts 1–14 and separate concurrent terms for counts 15–20, with the latter to run consecutively to the former. The defendant did not file a direct appeal. Later, he filed a motion under Wyoming Rule of Criminal Procedure 35(a) to correct what he argued was an illegal sentence, claiming that the multiple convictions and sentences violated double jeopardy protections because they arose from the same act. The district court denied the motion, finding the sentences appropriate based on the guilty pleas and the evidence of separate acts.The Supreme Court of Wyoming reviewed the case and held that the defendant’s double jeopardy claim was barred by res judicata because he could have raised it on direct appeal but did not, and he failed to show good cause for this omission. The court affirmed the district court’s denial of the motion to correct the sentence. However, the Supreme Court identified a discrepancy between the oral and written sentences and remanded the case to the district court solely to correct the written sentence so that it conforms to the oral pronouncement. View "Bernard v. The State of Wyoming" on Justia Law

Roberto Adams, a police officer, was convicted of wire fraud and money laundering related to the misuse of a small-business loan he received under the Paycheck Protection Program (PPP) of the Coronavirus Aid, Relief, and Economic Security Act. Adams did not testify at his trial, and his counsel requested a jury instruction to not draw any adverse inference from this decision. The district court agreed but inadvertently omitted the instruction. Adams' counsel failed to object until after the jury's verdict, which led to a motion for a new trial.The United States District Court for the District of Columbia granted Adams' motion for a new trial, finding that the omission of the no-adverse-inference instruction was plain error and prejudicial. The court noted that the government's case relied heavily on circumstantial evidence to prove Adams' knowledge and intent, and the jury's split verdict indicated that the case was close. The court concluded that the error likely affected the outcome of the trial.The United States Court of Appeals for the District of Columbia Circuit reviewed the case and affirmed the district court's decision. The appellate court agreed that the omission of the instruction was plain error and that it affected Adams' substantial rights. The court emphasized that the government's case was not overwhelming and relied on inferences from circumstantial evidence. The appellate court also found that the error seriously affected the fairness, integrity, and public reputation of the judicial proceedings, warranting a new trial. View "USA v. Adams" on Justia Law

Lauren, a thirteen-year-old girl, alleged that her father, Jobert Molde, sexually assaulted her between January 2011 and January 2012. These allegations surfaced in 2017 after Lauren attempted suicide. Molde was charged with first-degree sexual assault of a child under twelve and incest with a child. The key evidence against Molde included Lauren's in-court testimony and a recording of her forensic interview.The Dunn County Circuit Court allowed a nurse practitioner to testify as an expert, but she was unavailable, so Dr. Alice Swenson, a licensed child abuse pediatrician, testified instead. Dr. Swenson supervised Lauren's forensic interview but did not personally evaluate her. During the trial, a juror asked Dr. Swenson about the frequency of false sexual abuse disclosures, to which she responded that false disclosures are extraordinarily rare, around one percent. Molde's counsel did not object to this testimony. The jury found Molde guilty on both counts. Molde then moved for postconviction relief, arguing ineffective assistance of counsel for not objecting to Dr. Swenson's testimony. The circuit court denied the motion.The Wisconsin Court of Appeals held that Dr. Swenson's testimony constituted impermissible vouching and that Molde's attorney was ineffective for not objecting. The state petitioned for review, and the Wisconsin Supreme Court granted it.The Wisconsin Supreme Court concluded that Dr. Swenson's statistical testimony did not violate the Haseltine rule, which prohibits witnesses from vouching for another witness's credibility. The court held that statistical evidence alone about the prevalence of false reporting does not constitute impermissible vouching. Since Dr. Swenson did not opine on Lauren's truthfulness, Molde's counsel was not deficient for failing to object. Therefore, Molde's ineffective assistance of counsel claim failed, and the court reversed the decision of the court of appeals. View "State v. Molde" on Justia Law

In 2023, police in Des Moines, Iowa, received a tip about suspected narcotics trafficking at a residence. Acting under Iowa Code section 808.16, officers conducted warrantless searches of garbage bags placed curbside for collection. The searches revealed evidence of drug dealing, which was used to obtain a warrant to search the home, leading to further evidence and charges against two occupants, Charles Amble and John Mandracchia. The defendants moved to suppress the evidence, arguing that section 808.16 was unconstitutional.The Iowa District Court for Polk County ruled in favor of the defendants, declaring Iowa Code section 808.16 facially unconstitutional under article I, section 8 of the Iowa Constitution, as interpreted in State v. Wright. The court suppressed the evidence obtained from the garbage searches and the subsequent home search. The State appealed the decision.The Iowa Supreme Court reviewed the case and concluded that the district court erred in its ruling. The court held that the specific provision in Iowa Code section 808.16(3), which deems garbage placed outside for collection in a publicly accessible area as abandoned property, is constitutional both facially and as applied in this case. This provision preempts conflicting local ordinances and negates any reasonable expectation of privacy in such garbage. Consequently, the warrantless trash pulls conducted by the police were lawful, and the evidence obtained was admissible.The Iowa Supreme Court reversed the district court's suppression ruling and remanded the case for further proceedings consistent with its opinion. View "State of Iowa v. Amble" on Justia Law

Aldrick Scott was convicted of first-degree murder, use of a deadly weapon to commit a felony, and tampering with physical evidence after he shot and killed his former girlfriend, Cari Allen, in her home, buried her body, and disposed of other evidence. Scott claimed self-defense, stating that Allen had pulled a gun on him during an argument. However, evidence showed Scott had driven from Topeka to Omaha, where Allen lived, and waited outside her house before the incident. Scott's actions after the shooting, including disposing of Allen's body and other evidence, and fleeing to Belize, were also presented at trial.The District Court for Douglas County denied Scott's motion to suppress evidence obtained from his arrest and search by Belizean police, which included his cell phone. Scott argued that his arrest and search violated Belizean law and the extradition treaty between the United States and Belize, and that the evidence should be excluded under the Fourth Amendment. The court found that U.S. law enforcement did not substantially participate in Scott's arrest and search, and thus, the exclusionary rule did not apply.The Nebraska Supreme Court reviewed the case and affirmed the lower court's decision. The court held that the involvement of U.S. law enforcement did not amount to a joint venture with Belizean police, and thus, the Fourth Amendment's exclusionary rule did not apply. The court also found that any error in admitting the cell phone evidence was harmless, as it was cumulative of Scott's own testimony. Additionally, the court concluded that there was sufficient evidence for a rational trier of fact to find Scott guilty of all charges beyond a reasonable doubt. The court affirmed Scott's convictions and sentences. View "State v. Scott" on Justia Law

Following a high-speed chase, Kordell L. Grady was charged with multiple criminal offenses. He accepted a plea deal, pleading no contest to three charges. The dispute arose over whether Grady's due process rights were violated during a restitution hearing, where he was ordered to pay for damages caused to a law enforcement vehicle during the chase. Grady's counsel argued he lacked the ability to pay, and Grady, attending via Zoom, interrupted the proceedings. The court allowed him to speak with his attorney but warned that the conversation could be heard by everyone in the courtroom. Grady's statements undermined his counsel's argument, and the court ordered him to pay the full restitution amount.Grady filed a motion for postconviction relief, arguing that his due process rights were violated because he could not consult confidentially with his counsel, and that the Assistant District Attorney improperly used his statements. The circuit court rejected these arguments, finding that Grady did not intend for his conversation to be confidential. The court of appeals summarily affirmed the circuit court's decision.The Wisconsin Supreme Court reviewed the case and deferred to the circuit court's factual finding that Grady did not intend for his conversation with his counsel to be confidential. The Supreme Court held that Grady's due process rights were not violated, as he did not seek a confidential conversation. Consequently, his conversation was not privileged under Wisconsin Statute § 905.03(2). The decision of the court of appeals was affirmed. View "State v. Grady" on Justia Law

Mercedes B. Clark was stopped by Officer Ricky Robinson for speeding and driving on the wrong side of the road. During the stop, Officer Robinson smelled burnt marijuana and conducted a DUI investigation. A search of Clark's vehicle revealed a clutch bag containing a half-smoked marijuana joint, multicolored pills, and items with Clark's name. Clark admitted the bag was hers but claimed a male acquaintance had put his belongings in it, which she thought was marijuana.A Lauderdale County jury found Clark guilty of trafficking eutylone, a Schedule I controlled substance. The trial court sentenced her to ten years without parole. Clark's appellate counsel filed a brief under Lindsey v. State, stating no arguable issues for appeal. Clark filed a pro se supplemental brief raising three issues: the exclusion of her after-arrest interview, improper jury instructions, and a request for parole eligibility for first-time offenders.The Supreme Court of Mississippi reviewed the case. The court found that Clark had agreed to the exclusion of her interview with Agent Wilburn, making her argument on this point meritless. The court also determined that the jury instructions were proper, as they required the jury to find that Clark "unlawfully, wilfully, and feloniously" possessed the eutylone, which implicitly included the requirement of knowing possession. Lastly, the court noted that it does not have the authority to amend statutes, thus denying Clark's request for parole eligibility.The Supreme Court of Mississippi affirmed Clark's conviction and sentence, finding no arguable issues warranting relief. View "Clark v. State of Mississippi" on Justia Law