Justia Criminal Law Opinion Summaries

Law enforcement arrested an individual for operating under the influence after stopping him and bringing him to the police station. At the station, the officer explained the consequences of refusing a breath test, including administrative penalties and possible jail if the individual refused. After discussion and clarification that no additional charges would result from refusal, the individual agreed to take the breath test, although he initially stated he did not consent. The breath test was administered, and the individual was subsequently charged with criminal operating under the influence.The individual moved to suppress the breath test results in the Penobscot County Unified Criminal Docket, arguing that his consent to the test was not voluntary due to the officer’s statements and actions. The trial court denied the motion, citing Birchfield v. North Dakota, which held that warrantless breath tests incident to arrest do not require consent under the Fourth Amendment. After this ruling, the individual entered a conditional guilty plea, preserving his right to challenge the suppression ruling on appeal.The Supreme Judicial Court of Maine reviewed the case. The court held that, under Birchfield v. North Dakota, the Fourth Amendment allows warrantless breath tests as searches incident to arrest, and thus, the individual's consent was immaterial to the test’s admissibility. The court further concluded that the officer’s actions did not render the search unreasonable, as there were no false statements or arbitrary conduct, and the incentives provided by the officer were permissible. The court also held that the challenge must be analyzed under the Fourth Amendment rather than the Fourteenth Amendment’s Due Process Clause. Accordingly, the judgment was affirmed. View "State of Maine v. Davis" on Justia Law

A 15-year-old boy shot and killed his former girlfriend, a 17-year-old, after sending her harassing and threatening messages. The confrontation occurred at a park following an exchange with the victim’s cousin, which escalated into a plan to fight. The defendant brought his mother’s handgun to the scene and, during the confrontation, shot the victim in the face as she approached him. He was apprehended shortly after the shooting and confessed to law enforcement.The State originally charged the defendant with first-degree murder and misdemeanor stalking. Pursuant to a plea agreement, he pled guilty to second-degree murder and stalking. At sentencing, the prosecutor and defense agreed that an individualized hearing was appropriate, given the defendant’s juvenile status. The prosecution recommended a sentence of 44 to 75 years for the murder conviction, referencing Wyoming’s Bear Cloud line of cases and statutory limits for juvenile offenders. The defense argued that, under Wyoming law and constitutional principles, the maximum allowable sentence for a juvenile convicted of homicide should be 22.5 years to life, or at most a minimum term not exceeding 43 years. The District Court of Natrona County sentenced the defendant to 42 to 75 years for second-degree murder and time served for stalking.On appeal, the Supreme Court of the State of Wyoming reviewed whether (1) Wyoming’s juvenile parole eligibility statute applied, (2) the sentence exceeded statutory limits, and (3) the sentence violated the Wyoming Constitution’s prohibition on cruel or unusual punishment. The Court held that the parole eligibility statute applied only to life sentences, not to terms of years. The sentence fell within statutory limits for second-degree murder. Finally, the Court found the sentence was not “unusual” under the state constitution because there was no consensus among legislatures or courts that such a sentence for a juvenile was unlawful. The Supreme Court affirmed the district court’s judgment. View "Castaner v. The State of Wyoming" on Justia Law

The case involved allegations that a man sexually abused his stepdaughter, JB, when she was a child and later sexually assaulted his biological daughter, FO, when she was a teenager. After JB disclosed the abuse to her probation officer, both she and FO were interviewed by police and provided accounts implicating the defendant in two separate incidents of sexual intrusion. The State charged the defendant with two counts of first-degree sexual abuse of a minor.During trial proceedings in the District Court of Campbell County, the court granted the defendant’s motion to sequester witnesses. However, it was discovered that JB and FO overheard brief portions of a livestream of the trial while waiting to testify, in violation of the sequestration order. The district court questioned the witnesses outside the jury's presence, found no intentional or prejudicial violation, and allowed limited cross-examination on what they overheard, but did not permit questioning about their violation of a court order. The defendant also moved for mistrials based on allegedly improper testimony referencing uncharged conduct under Wyoming Rule of Evidence 404(b), but the court either struck the testimony and instructed the jury to disregard it or found the testimony did not reference uncharged acts, and denied the motions.On appeal, the Supreme Court of Wyoming reviewed whether the district court abused its discretion in limiting the scope of cross-examination and denying mistrials, and whether the defendant’s Confrontation Clause rights were violated. The court held that the district court acted within its discretion, as the violations of the sequestration order were minimal and non-prejudicial, and the limitations on cross-examination did not infringe on the defendant’s confrontation rights. The court also found no abuse of discretion in denying the motions for mistrial and found no cumulative error. The Supreme Court of Wyoming affirmed the convictions. View "O'Dell v. The State of Wyoming" on Justia Law

An individual reported to police that a debit card had been stolen from his car and used at a Southaven, Mississippi, Best Buy. The Southaven Police Department obtained receipt evidence and surveillance footage but did not immediately identify a suspect. Separately, police in another Mississippi county arrested Stephen Lewis for an unrelated burglary and searched his cell phone without a warrant, discovering images of receipts from the Southaven Best Buy. The investigating officer from the Washington County Sheriff’s Department shared these images with Detective Walley of the Southaven Police Department, informing her that a search warrant had been completed, though in reality, no warrant had been issued at the time. Walley reviewed the images, which matched the fraudulent purchase, and secured an arrest warrant for Lewis, who was later indicted; charges were eventually remanded.Lewis brought multiple constitutional claims under 42 U.S.C. § 1983 against Walley in the United States District Court for the Northern District of Mississippi. The district court dismissed all but one claim, allowing Lewis’s Fourth Amendment search claim to proceed. The district court found that Walley’s review of the photographs constituted a warrantless search, violating the Fourth Amendment, and denied Walley’s motion for judgment on the pleadings, as well as her qualified immunity defense.On appeal, the United States Court of Appeals for the Fifth Circuit reviewed the denial of qualified immunity de novo. The appellate court held that it was not clearly established at the relevant time that reviewing images of receipts from a phone, sent by another officer, constituted a Fourth Amendment search requiring a warrant. The court found that Walley’s reliance on information provided by the other officer was objectively reasonable. Therefore, the Fifth Circuit reversed the district court’s judgment and rendered a judgment of dismissal in Walley’s favor. View "Lewis v. Walley" on Justia Law

In the 1990s, Anthony M. Shea was involved in a series of bank and armored-car robberies in New Hampshire. In 1997, following a federal jury trial in the United States District Court for the District of New Hampshire, Shea was convicted on fourteen counts, including two counts of using or carrying a firearm during and in relation to a crime of violence under 18 U.S.C. § 924(c), and was sentenced to life imprisonment. The § 924(c) convictions were based on underlying predicate offenses, including substantive Hobbs Act robbery, conspiracy to commit Hobbs Act robbery, and bank robbery with a dangerous weapon. The jury returned a general verdict, finding Shea guilty of all counts.After his convictions were affirmed on direct appeal by the United States Court of Appeals for the First Circuit, Shea filed a motion under 28 U.S.C. § 2255 seeking to vacate his § 924(c) convictions and to be resentenced, arguing that subsequent Supreme Court decisions, particularly United States v. Davis and Johnson v. United States, rendered his predicate conspiracy offenses invalid for purposes of § 924(c). The District Court denied relief as to the § 924(c) convictions, finding any error in the jury instructions harmless, but granted resentencing because Shea’s "career offender" designation was no longer applicable.On appeal, the United States Court of Appeals for the First Circuit reviewed both the partial denial of Shea’s § 2255 motion and the amended judgment after resentencing. The First Circuit held that the District Court did not err in its harmless error analysis, finding that even though the jury was instructed on both valid and invalid predicate offenses, the valid predicates were so interrelated and coextensive with the invalid ones that the instructional error did not have a substantial and injurious effect on the verdict. The First Circuit affirmed both the denial of relief as to the § 924(c) convictions and the amended judgment. View "Shea v. United States" on Justia Law

Three individuals were prosecuted for their roles in a murder-for-hire scheme that resulted in the deaths of Holly Williams and William Lanway in Nashville. After one of the defendants, Maund, was blackmailed by Lanway following an affair with Williams, he hired Peled to address the situation. Peled then recruited Brockway, Carey, and others to surveil the victims, ultimately leading to their murders in March 2020. Substantial evidence was presented at trial, including recorded conversations, testimony from co-conspirators, financial records, and surveillance footage linking the defendants to the crimes.The United States District Court for the Middle District of Tennessee presided over the joint trial. The jury convicted all three defendants on various counts, including murder-for-hire conspiracy, and convicted Brockway and Carey on kidnapping-related charges. After the verdict, the district court discovered a critical error: the jury had received ten unadmitted exhibits—including recordings and transcripts not presented at trial—and had not received three admitted exhibits. Notably, among the unadmitted exhibits were statements concerning Carey’s knowledge of the crimes that had been excluded at trial. Following a post-verdict hearing, the district court concluded that this error was structural and required a new trial for all defendants, reasoning that the effects of the error were too difficult to measure.The United States Court of Appeals for the Sixth Circuit reviewed the district court’s grant of a new trial. The appellate court held that the erroneous jury exposure to unadmitted exhibits was not a structural error and was subject to harmless-error analysis. Applying the strictest harmless-error standard, the court found the error harmless beyond a reasonable doubt given the overwhelming evidence of guilt and the minimal prejudice to the defendants. The Sixth Circuit reversed the district court’s order granting a new trial and remanded for further proceedings. View "United States v. Maund" on Justia Law

Augustine Perez was on federal supervised release in North Carolina, subject to conditions that allowed warrantless searches of his “person and property” by probation officers. Perez moved from a residence at Teal Drive to Lawndale Drive, reporting the change as required, but retained ownership of Teal Drive and leased it to Deanna Coleman, who moved in with her daughter. About a year later, probation officers received a tip from a confidential informant that Perez was living at Teal Drive and involved in drug trafficking. Without a warrant, officers searched both Lawndale Drive and Teal Drive on the same day. At Teal Drive, Coleman objected to the search, but officers proceeded, finding cash and items they alleged were connected to drug trafficking.In the United States District Court for the Middle District of North Carolina, Perez and Coleman moved to suppress the evidence from the Teal Drive search, claiming it was unconstitutional. The district court denied the motion to suppress and granted summary judgment to the government, ruling that the currency found was subject to forfeiture as drug proceeds, largely relying on the evidence seized during the search.On appeal, the United States Court of Appeals for the Fourth Circuit reversed, vacated, and remanded. The court held that a supervised release condition permitting warrantless searches of a supervisee’s “property” does not authorize the search of real property owned by the supervisee but leased and occupied by a third party. The court further held that, to lawfully search Coleman’s residence under Perez’s supervision conditions, officers needed probable cause to believe Perez resided there. The government failed to meet this standard, rendering the search of Teal Drive unconstitutional. The Fourth Circuit ordered suppression of the evidence and dismissal of the forfeiture complaint. View "US v. Perez" on Justia Law

Three men—Clifton Mosley, Davon Carter, and Matthew Hightower—were involved in marijuana trafficking together. Hightower, who worked at a medical supply company, was indicted for healthcare fraud based on information provided by his coworker, Lisa Edmonds. After Hightower’s indictment, he, Carter, and Mosley allegedly conspired to retaliate against Edmonds, who was expected to testify against Hightower. On the morning Edmonds was scheduled for a court appearance, Carter fatally shot Edmonds’ neighbor, Latrina Ashburne, having apparently mistaken her for Edmonds. Surveillance footage, phone records, and witness testimony connected Mosley and Carter to the murder and to each other in the hours before the shooting.The United States District Court for the District of Maryland presided over the criminal proceedings. Carter and Mosley were jointly tried and convicted by a jury of witness-murder and marijuana trafficking. Mosley had moved to sever the murder and marijuana charges and to suppress evidence found on Carter, but the district court denied these motions, finding the offenses were properly joined under the Federal Rules, and that Mosley lacked standing to challenge the search of Carter’s property. A jury returned guilty verdicts on all counts, and Mosley received life imprisonment for the witness-murder counts and a concurrent sentence for marijuana distribution.The United States Court of Appeals for the Fourth Circuit reviewed Mosley’s appeal. The court held that joinder of the charges was proper, and the district court did not abuse its discretion in denying severance. The appellate court also held that Mosley lacked standing to challenge the suppression of evidence from Carter’s property. Finally, the Fourth Circuit concluded that substantial evidence supported the jury’s verdict. Accordingly, the court affirmed the district court’s judgment and upheld Mosley’s convictions. View "US v. Mosley" on Justia Law

Four individuals, including the defendant, regularly used a motel storage room for shelter and drug use. One night, after a dispute over missing drugs, the victim was severely beaten by two members of the group, including the defendant, and left in a bathtub where she died. The defendant was charged with murder under an accomplice liability theory. During trial preparations, the State informed the Allen Superior Court that one witness, Miquan Jones, was incarcerated four hours away and argued that the county lacked resources to transport him. Over the defendant’s objection, the court allowed Jones to testify remotely via live video. Jones testified that the defendant confessed to the murder and threatened him.The jury convicted the defendant, and the court imposed a sixty-three-year sentence. On appeal, the defendant argued, among other things, that the trial court erred in permitting virtual testimony because the State had not shown good cause as required by Interim Administrative Rule 14(C). The Indiana Court of Appeals affirmed, holding that good cause was shown and that confrontation rights were not violated, though one judge concurred only in result, finding any error harmless beyond a reasonable doubt.The Indiana Supreme Court granted transfer and vacated the appellate decision. The Supreme Court held that when the State seeks to present remote testimony against a criminal defendant, it must provide case-specific evidence showing that remote testimony is necessary to prevent a concrete and substantial harm that cannot otherwise be addressed. The State’s argument based on logistical inconvenience did not meet this standard, so the trial court abused its discretion. However, the Supreme Court found the error harmless given the overwhelming independent evidence of guilt and affirmed the conviction. View "Shabazz v. State of Indiana" on Justia Law

The case concerns a defendant who, as the sole operator of a clean energy startup, misled investors by supplying them with altered documents, forged signatures, and false financial information to exaggerate his company’s position and prospects. After obtaining nearly $1 million from a university-affiliated incubator and several individual investors, he quickly withdrew large sums, routed money through his own accounts in suspicious transfers, and used most of the funds to purchase a personal residence. He repeatedly lied to investors and federal agents to conceal his activities. Despite red flags, the investors disbursed funds based on his representations.A federal grand jury in the United States District Court for the Middle District of Pennsylvania indicted him on multiple counts, including wire fraud, mail fraud, aggravated identity theft, money laundering, unlawful monetary transactions, obstruction of justice, and making false statements. At trial, the defendant made a generalized motion for acquittal under Rule 29, which the District Court denied. The jury found him guilty on all counts. The District Court sentenced him to 72 months in prison and imposed over $1.1 million in restitution, later amended to include attorneys’ fees incurred by the victims.On appeal to the United States Court of Appeals for the Third Circuit, the defendant raised sufficiency-of-the-evidence challenges, argued instructional error regarding the aggravated identity theft counts, and disputed the restitution award for attorneys’ fees. The Third Circuit held that a non-specific Rule 29 motion does not preserve all sufficiency arguments for appeal and that, under plain-error review, the evidence supported all convictions. The court found no instructional error or constitutional vagueness in the aggravated identity theft statute. However, it held that the Mandatory Victims Restitution Act does not authorize restitution for attorneys’ fees. The convictions and sentence were affirmed, the restitution order for attorneys’ fees was vacated, and the case was remanded for entry of an amended judgment. View "USA v. Abrams" on Justia Law