Justia Criminal Law Opinion Summaries

Law enforcement conducted a warrant-backed search of an apartment occupied by Tyrone Fulwiley and Deandre Maxwell, uncovering firearms, cocaine, and drug distribution paraphernalia. Maxwell pleaded guilty to charges of possession of cocaine with intent to distribute, possession of a firearm in furtherance of a drug trafficking offense, and possession of a firearm by a felon. Fulwiley went to trial and was convicted on all counts by a jury. Both defendants challenged the search, the denial of a Franks hearing, and the refusal to reveal the identity of the confidential informant. Fulwiley also contested the sufficiency of the evidence supporting his conviction.The United States District Court for the Central District of Illinois denied the defendants' motions to suppress evidence, for a Franks hearing, and to reveal the informant's identity. Fulwiley's motion for a judgment of acquittal was also denied. Maxwell pleaded guilty, while Fulwiley was convicted by a jury based on evidence including testimony from law enforcement and a forensic expert linking him to the drugs and firearms found in the apartment.The United States Court of Appeals for the Seventh Circuit reviewed the case and affirmed the district court's decisions. The appellate court held that the search warrant was supported by probable cause, given the detailed and corroborated information provided by the confidential informant. The court also found no error in the denial of a Franks hearing, as the defendants failed to make a substantial preliminary showing of a material falsity or omission in the warrant affidavit. Additionally, the court upheld the decision not to reveal the informant's identity, as the informant was deemed a mere tipster and not essential to the defense. Finally, the court found sufficient evidence to support Fulwiley's convictions, including his constructive possession of the drugs and firearms and the nexus between the firearms and drug trafficking activities. View "United States v. Maxwell" on Justia Law

Meredith Logan Whitehurst was cited for violating the Town of Sullivan's Island's Disorderly Conduct Ordinance after loudly berating her Uber driver with profanity and racial and xenophobic epithets at nearly 2:00 a.m. The driver, an Egyptian-born immigrant, testified that Whitehurst's loud phone conversation disturbed his driving, and when he asked her to be quiet, she began mocking and cursing him. After stopping the car and asking Whitehurst and her friend to exit, Whitehurst continued to yell offensive remarks at the driver. The police were called, and Whitehurst was cited for public disorderly conduct.Whitehurst was tried by a jury in the Town's Municipal Court, which found her guilty and fined her $1,040. She moved for a new trial, which was denied, and then appealed to the circuit court, which affirmed the conviction. Whitehurst then appealed to the South Carolina Supreme Court, arguing that the Ordinance violated her First Amendment rights, was unconstitutionally vague, and that the trial court erred in various procedural rulings, including denying her motion to suppress the Uber video.The South Carolina Supreme Court affirmed the lower court's decision. The Court held that the Ordinance was content-neutral and served the Town's significant interest in controlling noise levels, thus not infringing on Whitehurst's First Amendment rights. The Court also found that the Ordinance was not unconstitutionally vague, as it provided fair notice of the prohibited conduct and included a scienter requirement. Additionally, the Court deemed Whitehurst's arguments regarding the multiple subsections of the Ordinance and the motion to suppress the Uber video as conclusory and abandoned due to lack of supporting authority. View "Whitehurst v. Town of Sullivan's Island" on Justia Law

Charles Dent was accused of sexually abusing his granddaughter, J.M., when she was eight or nine years old. The alleged abuse occurred during periods when Dent visited his daughter’s family in South Carolina. The victim disclosed various acts of abuse, including being forced to perform fellatio, digital penetration, cunnilingus, and being shown obscene material. The State indicted Dent on two counts of disseminating obscene material to a minor and two counts of criminal sexual conduct with a minor (CSCM) in the first degree, specifically alleging fellatio as the sexual battery in both CSCM indictments.At trial in the Circuit Court for Beaufort County, the State presented evidence through forensic interviews and the victim’s testimony. The victim described only one instance of fellatio, which she located at House 1, not House 2. Dent moved for a directed verdict on the CSCM charge related to House 2, arguing there was no evidence of fellatio at that location. The trial court denied the motion and, over Dent’s objection, instructed the jury on the full statutory definition of sexual battery, including acts not charged in the indictment. The jury convicted Dent of the CSCM charge for House 2 and both dissemination charges, but acquitted him of the CSCM charge for House 1. The South Carolina Court of Appeals affirmed the convictions after remand.The Supreme Court of South Carolina held that the trial court erred by denying Dent’s motion for a directed verdict on the CSCM charge for House 2, as there was no evidence of fellatio at that location, and by instructing the jury on unindicted acts of sexual battery. The Court reversed Dent’s CSCM conviction but affirmed his convictions for dissemination of obscene material to a minor. The Court also rejected Dent’s procedural challenge regarding the composition of the appellate panel. View "State v. Dent" on Justia Law

The defendant was convicted of operating a motor vehicle after his license had been revoked. The revocation was due to a prior conviction for motor vehicle homicide and operating under the influence (OUI). The defendant argued that his motion to dismiss the complaint should have been allowed because the citation was not issued at the time and place of the violation, as required by the "no-fix" statute. The police learned of the violation weeks later through a television news report and issued the citation after investigating the report.In the Dedham Division of the District Court Department, the defendant's motion to dismiss was denied. The judge found that additional time was reasonably necessary to investigate the violation. The defendant's motion for reconsideration was also denied. At trial, the judge found the defendant guilty and sentenced him to eighteen months in a house of correction. The defendant appealed, and the Supreme Judicial Court granted direct appellate review.The Supreme Judicial Court of Massachusetts affirmed the lower court's decision. The court held that the delay in issuing the citation was justified because additional time was reasonably necessary to investigate the violation. The court also found that the evidence was sufficient to prove that the defendant operated a motor vehicle after his license had been revoked and before it was restored. The court rejected the defendant's argument that the penalty only applied during the pendency of the revocation period, clarifying that the penalty continues to apply until the license or right to operate is restored. The judgment was affirmed. View "Commonwealth v. Foley" on Justia Law

In 2014, Mikel Mims pleaded guilty to conspiracy to commit wire fraud and was sentenced to three years of probation and ordered to pay $255,620 in restitution. After completing her probation in 2017, Mims stopped making restitution payments. In 2022, the district court ordered Mims to resume her restitution payments, prompting Mims to appeal, arguing that the court lacked jurisdiction and violated her due process rights.The district court for the Southern District of Florida initially expressed doubts about its jurisdiction after Mims's probation ended. However, after the government filed a motion and Mims responded, the court concluded it had jurisdiction under various statutory provisions and ordered Mims to comply with the original restitution order, including making up for missed payments.The United States Court of Appeals for the Eleventh Circuit reviewed the case and affirmed the district court's decision. The appellate court held that the district court had ancillary jurisdiction to enforce its restitution order, as it was part of Mims's original criminal sentence. The court also found that Mims had been given adequate notice and opportunities to be heard, satisfying due process requirements. The Eleventh Circuit concluded that the district court did not err in ordering Mims to resume her restitution payments and affirmed the lower court's decision. View "United States v. Mims" on Justia Law

Perrie Thompson was sentenced to 50 years to life for a homicide he committed at age 17. Fifteen years later, he petitioned for relief under Penal Code section 1170(d), which allows juvenile offenders sentenced to life without parole to seek resentencing. Thompson argued that his sentence was effectively life without parole and cited cases like People v. Contreras and People v. Heard to support his claim. He presented evidence of his rehabilitation efforts while incarcerated. The trial court denied his petition, stating that his sentence was not equivalent to life without parole since he would be eligible for parole within his life expectancy.Thompson appealed the decision. The Attorney General initially opposed the appeal but later conceded that a 50-years-to-life sentence is functionally equivalent to life without parole and that denying relief to such offenders violates equal protection. However, the court independently reviewed the merits of Thompson's arguments.The California Court of Appeal, Second Appellate District, Division Three, affirmed the trial court's order. The court held that Thompson's 50-years-to-life sentence is not the functional equivalent of life without parole for equal protection purposes. The court reasoned that the legislative intent behind section 1170(d) was to address the most severe punishments, specifically life without parole, and that the Legislature could rationally distinguish between life without parole and lengthy term-of-years sentences. The court concluded that Thompson failed to demonstrate that the exclusion of his sentence from section 1170(d) relief was irrational or unconstitutional. View "People v. Thompson" on Justia Law

The defendant and the victim were involved in a fatal shooting that occurred outside the home of the defendant’s former partner, with whom he shared a child. After the end of their romantic relationship, the former partner began seeing the victim. On the night in question, the victim arrived at the former partner’s house, and after an encounter between the defendant and his former partner, the defendant fired multiple gunshots into the victim’s car, resulting in the victim’s death. The defendant was subsequently indicted on multiple charges, including murder and several related offenses. Additional charges were brought based on the defendant’s conduct while incarcerated awaiting trial. The two cases were consolidated and tried together.In the Providence County Superior Court, the defendant was tried before a jury. The trial justice included an instruction on voluntary manslaughter over the state’s objection, but instructed the jury to consider voluntary manslaughter only if it found the state had not proven first- or second-degree murder beyond a reasonable doubt. The defendant objected, arguing that the jury should be allowed to consider whether adequate provocation negated malice even if the elements of murder were otherwise satisfied, and that the state should be required to disprove provocation beyond a reasonable doubt. The jury found the defendant guilty of second-degree murder and several other charges, and not guilty on others. The defendant was sentenced accordingly and appealed.The Supreme Court of Rhode Island reviewed the case. The court held that the trial justice’s instructions were proper, finding that the instructions, when viewed in their entirety, adequately explained the law and did not mislead the jury. The court concluded that the state’s burden of proof was not improperly shifted to the defendant and that the instructions did not violate due process. The judgments of conviction were affirmed. View "State v. Mangru" on Justia Law

Malcolm Wilson, an inmate at Indiana State Prison, was involved in an altercation where he grabbed another inmate's cane to defend himself, causing the other inmate to fall and require medical attention. Wilson was charged with battery and, after a disciplinary hearing conducted by Lieutenant Angelita Castaneda, was found guilty. Castaneda imposed a sentence that included 90 days in restrictive housing, a demotion in credit class, and up to $100,000 in restitution for medical costs.The United States District Court for the Northern District of Indiana dismissed Wilson's pro se complaint at the screening stage under 28 U.S.C. § 1915A, finding that there was sufficient evidence to support the restitution order. Wilson's motion for reconsideration was also denied. Wilson appealed the dismissal, arguing that the restitution amount was not supported by any evidence.The United States Court of Appeals for the Seventh Circuit reviewed the case de novo, accepting the factual allegations in Wilson's complaint as true. The court found that the evidence presented at the disciplinary hearing, including Wilson's statements, video footage, and staff conduct reports, constituted "some evidence" to support the restitution order. The court held that the procedural requirements of due process were met, as Wilson received notice of the charges, an opportunity to defend himself, and a written statement of the evidence and reasons for the disciplinary action. The court affirmed the district court's judgment, concluding that Wilson received the process he was due. View "Wilson v. Castaneda" on Justia Law

Charles Rowe pleaded guilty to three federal crimes and was sentenced to 360 months in prison. He had a prior conviction for cocaine trafficking under Florida law. The district court determined that this prior conviction was a controlled substance offense, triggering a sentencing enhancement under the career offender guidelines. Rowe appealed, challenging the legitimacy of his guilty plea and the enhanced sentence.The United States District Court for the Northern District of Florida accepted Rowe's guilty plea after a thorough plea colloquy conducted by a magistrate judge. The probation office recommended an enhanced sentence under the Armed Career Criminal Act and the career offender guidelines due to Rowe's prior convictions. Rowe objected, arguing that his prior conviction for cocaine trafficking did not qualify as a controlled substance offense. The district court held the sentencing in abeyance pending a decision from the Florida Supreme Court on a related issue. After the Florida Supreme Court's decision, the district court applied the enhanced sentence and sentenced Rowe to 360 months in prison.The United States Court of Appeals for the Eleventh Circuit reviewed the case. The court held that the Florida Supreme Court's decision in Conage II clarified that a conviction for cocaine trafficking under Florida law requires proof of possession with intent to distribute, aligning it with the federal definition of a controlled substance offense under the career offender guidelines. The court concluded that Rowe's prior conviction was a controlled substance offense and upheld the enhanced sentence. The court also found that the district court properly substantiated and accepted Rowe's guilty plea. Consequently, the Eleventh Circuit affirmed Rowe's conviction and sentence. View "United States v. Rowe" on Justia Law

The defendant, Matthew Raymond, was convicted by a jury in the Superior Court on four counts of second-degree assault, six counts of simple assault-domestic violence, one count of false imprisonment, and one count of misdemeanor criminal mischief. The incidents occurred in May and June 2022, but the victim did not report them until August 2022. The defendant was subsequently charged with these offenses.Before the trial, the State intended to call Dr. Scott Hampton, an expert in intimate partner violence, to testify. The defendant moved to exclude Hampton’s testimony, arguing it was unreliable under RSA 516:29-a. The State countered that Hampton would provide general education on domestic violence dynamics without discussing the specific facts of the case. The Trial Court held an evidentiary hearing and found Hampton qualified to offer expert opinions in the field of intimate partner violence, allowing his testimony with limitations. The jury trial proceeded, and the defendant was convicted on most charges, leading to this appeal.The Supreme Court of New Hampshire reviewed the case and upheld the trial court’s decision to admit Hampton’s testimony. The court found that Hampton’s extensive experience and specialized knowledge in domestic violence met the reliability standards under New Hampshire Rule of Evidence 702 and RSA 516:29-a. The court noted that Hampton’s testimony was based on his experience with thousands of domestic violence victims and offenders over two decades, which provided a sufficient basis for his general education testimony. The court also distinguished this case from State v. Keller, where the expert’s methodology was applied to the specific facts of the case. Here, Hampton’s testimony was general and not case-specific, making the RSA 516:29-a, II(a) factors less applicable. Consequently, the court affirmed the trial court’s ruling, finding no reversible error. View "State v. Raymond" on Justia Law