Justia Criminal Law Opinion Summaries

Lucianna Nicole Fox was convicted of felony murder and other crimes related to the shooting death of Leroy Midyette. On November 5, 2016, Fox encountered Midyette at a MARTA station. After a confrontation where Midyette did not move his cart out of the way, Fox hit the cart with her vehicle. Midyette followed her car and hit it, prompting Fox to exit her vehicle and shoot him, claiming she felt threatened. Fox was arrested and, during a police interview, stated she shot Midyette because she feared he had a weapon.Fox was indicted by a Fulton County grand jury and found guilty of felony murder, aggravated assault, and possession of a firearm during the commission of a felony. She was sentenced to life with the possibility of parole for felony murder and an additional five years for the firearm charge. Her motion for a new trial was denied by the trial court.The Supreme Court of Georgia reviewed the case. Fox argued that her trial counsel was ineffective for not requesting a jury charge on the defense of accident and that the trial court committed plain error in its jury instructions. The court found that her counsel’s decision to focus solely on self-defense was not unreasonable and did not constitute ineffective assistance. The court also determined that any error in the jury instructions did not likely affect the trial's outcome. Consequently, the court affirmed Fox’s convictions, finding no cumulative error that denied her a fair trial. View "FOX v. THE STATE" on Justia Law

John Paul Jones was found guilty by a jury of malice murder and related crimes for the shooting death of his brother-in-law, Michael Robinson. The incident occurred after an exchange of antagonistic messages on social media, leading Robinson to visit Jones's house. Upon arrival, Jones shot Robinson, who was unarmed, and also pointed a gun at Robinson's wife, who managed to escape and call 911. Robinson died from gunshot wounds, with evidence suggesting he was shot while on the ground.Jones was indicted by a Polk County grand jury and found guilty on all counts in December 2014. He was sentenced to life in prison without parole for malice murder, with additional consecutive sentences for other charges. Jones filed a motion for a new trial, which was denied without a hearing in March 2020. He then filed a notice of appeal, and new counsel was appointed. The case was remanded to address claims of ineffective assistance of trial counsel. After a hearing, the trial court denied the amended motion for a new trial in May 2024, and Jones appealed.The Supreme Court of Georgia reviewed the case and addressed Jones's claim that his trial counsel was ineffective for not requesting a timely hearing on his motion for a new trial. The court found that Jones did not have a right to have the same judge who presided over his trial consider his general-grounds claim. The court concluded that Jones failed to demonstrate deficient performance by his counsel and affirmed the trial court's decision. View "JONES v. THE STATE" on Justia Law

In February 2019, Beal Hickman pled no contest to voluntary manslaughter and was sentenced to 21 years in prison for the 2014 killing of Chadwick Brice. Hickman later filed a petition for resentencing under Penal Code section 1172.6, arguing that changes in the law under Senate Bill No. 1437, which altered the law of imputed malice, should apply to his case. He claimed that he could not be convicted of murder or attempted murder under the new legal standards.The Contra Costa County Superior Court denied Hickman's petition, relying on the precedent set by People v. Reyes, which held that defendants who were convicted by plea after Senate Bill No. 1437 took effect are ineligible for relief under section 1172.6. The court concluded that since Hickman entered his plea after the effective date of the legislation, he could not demonstrate that he could not be convicted of murder or attempted murder due to the changes enacted by Senate Bill No. 1437.The California Court of Appeal, First Appellate District, reviewed the case and affirmed the lower court's decision. The appellate court agreed with the reasoning in Reyes and other similar cases, such as People v. Lezama and People v. Gallegos, which held that defendants who were convicted by plea after the effective date of Senate Bill No. 1437 are categorically ineligible for relief under section 1172.6. The court rejected Hickman's arguments that the law was unsettled after the effective date of Senate Bill No. 1437 and concluded that he had already received the benefits of the legislative changes. Therefore, the order denying Hickman's petition for resentencing was affirmed. View "People v. Hickman" on Justia Law

Ryan Anderson pled guilty to multiple charges, including second-degree robbery, grand theft, retail theft, and second-degree burglary. These charges stemmed from a scheme where he stole "Scratchers" lottery tickets from various retailers and redeemed the winning tickets for prize money. The trial court ordered Anderson to pay $179,231.65 in restitution to the California State Lottery, which included the value of the stolen tickets, the prize money he collected, and commissions paid to retailers.The trial court's restitution order was based on a detailed chart presented by the prosecution, which outlined the value of the stolen tickets, the amounts reimbursed to retailers by the Lottery, and the prize money Anderson collected. Anderson did not dispute the Lottery's entitlement to recoup the prize money and retailer commissions but argued that the prize money should have been deducted from the retail value of the stolen tickets. The trial court rejected this argument, finding that the stolen tickets represented lost sales revenue.The California Court of Appeal, First Appellate District, reviewed the case. Anderson's appellate counsel filed a brief under People v. Wende, identifying no specific issues for appeal. The appellate court conducted an independent review and invited supplemental briefs on whether the trial court abused its discretion in calculating the restitution award. The appellate court affirmed the trial court's decision, holding that the restitution order was appropriate and that the Lottery did not receive a windfall. The court found that the Lottery's reimbursement to retailers shifted the loss from the retailers to the Lottery, and Anderson was responsible for the full amount of the stolen tickets' retail value, the prize money he collected, and the retailer commissions. The judgment was affirmed. View "People v. Anderson" on Justia Law

Edward C. Brown was convicted of distribution and possession of child pornography in 2015. After serving his prison sentence, he was placed on supervised release with conditions, including allowing unannounced visits by probation officers and reporting any cell phones he possessed. During an unannounced visit in April 2023, probation officers discovered an unreported cell phone in Brown's apartment. A forensic search of the phone revealed 75 thumbnail images of child pornography in an inaccessible cache folder. Brown was subsequently charged with possession of child pornography and convicted by a jury.The United States District Court for the Central District of Illinois admitted Brown's prior child pornography convictions as evidence under Federal Rules of Evidence 414 and 404(b). The court also allowed evidence of Brown's supervised release status. At trial, the jury heard testimony from government witnesses, including a probation officer, a police detective, and an FBI special agent, as well as defense witnesses who highlighted deficiencies in the forensic evidence. Despite the lack of metadata and direct evidence linking Brown to the images, the jury found him guilty. The district court denied Brown's motion for acquittal and sentenced him to 78 months in prison, followed by a 15-year term of supervised release. The court also revoked his supervised release from prior convictions, adding a consecutive 6-month prison term.The United States Court of Appeals for the Seventh Circuit reviewed the case and affirmed Brown's conviction. The court held that the combination of the 75 thumbnail images, Brown's prior convictions, his interview admissions, and his failure to report the phone provided sufficient circumstantial evidence for a reasonable jury to find him guilty beyond a reasonable doubt. The court emphasized that the forensic evidence, while flawed, was supported by other incriminating factors, including Brown's technological knowledge and his concealment of the phone from probation. View "USA v Brown" on Justia Law

A jury convicted the defendant of five counts of first-degree murder after five firefighters died while fighting a wildland fire that the defendant started. The jury also convicted the defendant of 20 counts of arson and 17 counts of possession of an incendiary device, with true findings on arson-murder and multiple-murder special-circumstance allegations. The jury returned a death verdict, and the trial court denied the defendant’s motion to reduce the death verdict, sentencing him to death and 28 years on the remaining convictions.The trial court denied the defendant’s motion for a change of venue, finding that the county’s population was large enough to provide a pool of jurors who were not familiar with the case. The court also excluded a juror who expressed uncertainty about considering both penalty options. The defendant’s challenges to the sufficiency of the evidence supporting his convictions and special-circumstance findings were rejected, as substantial evidence supported the jury’s findings.The court admitted evidence of two uncharged fires to show the defendant’s lack of remorse, finding it relevant to the circumstances of the crime. The court also admitted autopsy photos and victim impact testimony, which the defendant argued were unduly prejudicial. The court found the evidence relevant to the circumstances of the crime and not unduly prejudicial.The defendant’s challenges to California’s death penalty statute and the court’s interpretation thereof were rejected, as the court adhered to its precedent. The court concluded that any assumed instructional error regarding the arson-murder special circumstance was harmless beyond a reasonable doubt. The judgment was affirmed in its entirety. View "P. v. Oyler" on Justia Law

In August 2021, five defendants responded to online advertisements offering sexual services for a fee. The advertisements, posted by undercover police officers, depicted an adult woman and listed various sexual services. Each defendant contacted the purported sex worker, selected services, agreed to the set price, and went to the specified location. Upon arrival, they were arrested by police officers.A Plymouth County grand jury indicted each defendant for trafficking of persons for sexual servitude under G. L. c. 265, § 50, and engaging in sexual conduct for a fee under G. L. c. 272, § 53A. The defendants moved to dismiss the sex trafficking charges, arguing that the facts did not support probable cause. A Superior Court judge allowed the motions, reasoning that the defendants did not attempt to traffic "another person" since the sex worker was an undercover officer. The Commonwealth appealed, and the Appeals Court affirmed the dismissal, concluding that the evidence did not constitute trafficking of a person for sexual servitude. The Commonwealth then sought further appellate review.The Supreme Judicial Court of Massachusetts reviewed the case and affirmed the dismissal of the sex trafficking indictments. The court held that the defendants' conduct of responding to advertisements, agreeing to terms, and going to the location did not constitute "trafficking of persons for sexual servitude" under G. L. c. 265, § 50. The court concluded that the statute did not apply to purchasers who respond to offers from independent sex workers and accept the terms set by the sex worker. The court emphasized that the statute targets those involved in the operation of sex trafficking schemes, not the subset of purchasers targeted by the sex for a fee statute. The case was remanded for further proceedings on the remaining indictments. View "Commonwealth v. Garafalo" on Justia Law

In September 2022, the defendant used a short-term rental home in Tulsa, Oklahoma, to distribute fentanyl pills. The rental was booked by an unindicted female co-conspirator through Airbnb.com. The property manager, Mallory Massey, visited the rental on September 9 and found the master-bedroom door locked. The defendant opened the door and explained that he had been using the back door. On September 15, police observed the defendant selling fentanyl pills at the rental. A search warrant executed on September 19 led to the discovery of fentanyl, marijuana, scales, firearms, ammunition, cash, and personal belongings, resulting in the defendant's arrest.The defendant was indicted by a grand jury on charges of possession of fentanyl with intent to distribute, possession of firearms in furtherance of a drug-trafficking crime, and being a felon in possession of a firearm and ammunition. He was convicted on all counts following a jury trial. The presentence investigation report recommended a two-level enhancement under U.S.S.G. § 2D1.1(b)(12) for maintaining a premises for drug distribution. The defendant objected, arguing there was no evidence he maintained the house. The district court applied the enhancement, finding that the defendant solely occupied the residence and used it primarily for drug distribution.The United States Court of Appeals for the Tenth Circuit reviewed the case. The court held that the enhancement was appropriate, as the defendant exercised control over the rental, stored drugs and personal belongings there, and used it for drug distribution. The court affirmed the district court's application of the enhancement and the defendant's sentence of 248 months' imprisonment. View "United States v. Day" on Justia Law

The State charged Larry Joe Foster with second-degree intentional murder for the death of Daniel Bradley. Foster claimed that another person, R.J., committed the murder. The district court determined that Foster met the requirements to present an alternative perpetrator defense and allowed him to introduce evidence supporting his claim. Foster intended to call R.J. as a witness, but R.J. invoked his right against self-incrimination before the trial. Foster requested that R.J. be required to invoke this right in front of the jury, but the district court denied the request, citing the lack of probative value and the cumulative nature of the evidence.The jury found Foster guilty of second-degree murder. Foster appealed, arguing that the district court violated his constitutional rights by not allowing him to call R.J. to the stand. The Minnesota Court of Appeals affirmed Foster’s conviction, concluding that he had no constitutional right to call R.J. solely to invoke his right against self-incrimination.The Minnesota Supreme Court reviewed the case and held that when a defendant has satisfied the required test to present an alternative perpetrator defense, the district court has discretion to allow the defendant to call the alternative perpetrator as a witness, even if it is known that the alternative perpetrator will invoke their right against self-incrimination. However, the district court must apply the ordinary rules of evidence in making this determination. The Supreme Court concluded that the district court did not abuse its discretion in denying Foster’s request, as the invocation of the right against self-incrimination by R.J. would have been needlessly cumulative. The decision of the court of appeals was affirmed on different grounds. View "State v. Foster" on Justia Law

Eloisa Rubi Plancarte was convicted of misdemeanor indecent exposure under Minnesota Statutes section 617.23, subdivision 1(1) for exposing her breasts in a gas station parking lot. Plancarte argued that her breasts are not "private parts" under the statute and that her exposure was not "lewd." She also claimed that prosecuting her for conduct that men are allowed to engage in violated her constitutional right to equal protection. The district court denied her motion to dismiss, and she was found guilty in a stipulated-evidence trial.Plancarte appealed her conviction, but the court of appeals affirmed it in a divided opinion. The majority concluded that the evidence was sufficient to support the conviction, while the dissent argued that the statute requires lewd conduct in addition to exposure, which was not proven in this case.The Minnesota Supreme Court reviewed the case and concluded that the term "lewdly" in the statute refers to conduct of a sexual nature. The court found that the State did not present sufficient evidence to prove that Plancarte's exposure was lewd, as there was no indication that her conduct was of a sexual nature. Consequently, the court reversed Plancarte's conviction. The court did not address whether female breasts are "private parts" under the statute or the equal protection claim, as the decision on the lewdness element resolved the case. View "State v. Plancarte" on Justia Law