Justia Criminal Law Opinion Summaries

In 2002, Fred Williamson was fatally shot while in a car in Minneapolis. B.H., a passenger in Williamson's car, initially claimed he did not see the shooter. Later, B.H. was indicted on unrelated federal drug charges and agreed to provide substantial assistance in Williamson's murder investigation in exchange for a potential sentence reduction. At trial, B.H. identified Leroy Roderick Paul as the shooter. Paul was convicted of first-degree murder during a drive-by shooting and sentenced to life in prison. His conviction was affirmed on direct appeal.Paul filed a petition for postconviction relief in 2023, claiming the State violated Brady v. Maryland and Giglio v. United States by not disclosing the specific terms of B.H.'s plea agreement. The district court denied the petition without an evidentiary hearing, finding no factual support for Paul's claim and determining the petition was untimely under the two-year statutory time bar.The Minnesota Supreme Court reviewed the case and affirmed the district court's decision. The court held that the evidence presented by Paul, even if accepted as true, did not support his claim that B.H. had negotiated a specific sentence. The court also found that Paul's petition was untimely and did not meet the exceptions for newly discovered evidence or interests of justice. The court concluded that the district court did not abuse its discretion in summarily denying the petition. View "Paul v. State" on Justia Law

In 2014, federal law enforcement began investigating a website known as "Playpen," used to distribute child pornography. The Department of Justice obtained a warrant to reveal the IP addresses of Playpen users, leading to the identification of Eric Schuster in Ohio. A search of Schuster's residence uncovered multiple devices containing thousands of images and videos of child pornography. In May 2016, Schuster was indicted on three felony child pornography counts and detained pretrial.The case experienced significant delays in the district court. Initially, Schuster requested several continuances to review discovery and prepare motions. Over the next three years, Schuster's litigation conduct, including filing and withdrawing motions and requesting new counsel, contributed to the delays. In April 2019, Schuster's motions were fully briefed, but the district court took no action for twenty months. In December 2020, Schuster requested a status conference, and the court stayed proceedings for additional discovery. Another eighteen months passed without action on Schuster's motions.Schuster moved to dismiss his indictment in August 2022, arguing the delay violated his Sixth Amendment right to a speedy trial. The district court initially denied the motion but later reconsidered and dismissed the indictment with prejudice, finding the delay attributable to the court and the impact of incarceration during the COVID-19 pandemic.The United States Court of Appeals for the Sixth Circuit reviewed the case and applied the Barker v. Wingo factors. The court found that Schuster was responsible for much of the delay and failed to assert his right to a speedy trial in a timely and consistent manner. Additionally, Schuster did not demonstrate substantial prejudice resulting from the delay. The court concluded that Schuster's Sixth Amendment right was not violated and reversed the district court's decision, allowing the prosecution to proceed. View "United States v. Schuster" on Justia Law

Brian Allen Merchant Jones was indicted for conspiracy to commit felony controlled substance offenses, use of a firearm in the commission of a felony, possession of a firearm by a prohibited person, and involuntary manslaughter after he shot and killed his friend, Zackerie Howser, on September 15, 2020. The victim and Jones were involved in drug trafficking, and the shooting occurred shortly after Jones arrived at the victim's home to deliver methamphetamine. Jones pled guilty to possession of a firearm by a prohibited person and involuntary manslaughter but proceeded to trial on the conspiracy and firearm charges.The Circuit Court of Marion County convicted Jones of conspiracy to commit felony controlled substance offenses and use of a firearm in the commission of a felony. Jones filed post-trial motions for judgment of acquittal and a new trial, which were denied. He was sentenced to fifteen years for conspiracy, ten years for use of a firearm, five years for possession of a firearm by a prohibited person, and one year for involuntary manslaughter.The Supreme Court of Appeals of West Virginia reviewed the case and affirmed the lower court's decision. The court held that the hearsay testimony regarding the victim's statements about drug sales was admissible under Rule 804(b)(3) as statements against interest by an unavailable declarant. The court also found that the prosecutor's comments about Jones's flight during closing arguments, although improper, did not render the trial unfair. The court concluded that the evidence of Jones's involvement in the drug conspiracy and the use of a firearm during the commission of a felony was sufficient to support his convictions. The court affirmed the circuit court's judgment and sentencing order. View "State v. Jones" on Justia Law

Alberto Lopez-Barraza was convicted of robbery and murder related to the 2011 killing of Jose Manuel de Jesus but was acquitted of conspiracy to commit robbery. He appealed the denial of his petition for resentencing under Penal Code section 1172.6, arguing that the trial court improperly relied on factual findings that conflicted with the jury's determination that he was not guilty of conspiracy.Initially, Lopez-Barraza and his co-defendants were charged with murder, conspiracy to commit robbery, and robbery, with additional allegations related to firearm use. Lopez-Barraza was found guilty of murder and robbery, but not conspiracy. His murder and robbery convictions were affirmed on appeal, but the special circumstance finding was reversed due to instructional error. On remand, the special circumstance was not retried, and Lopez-Barraza was resentenced to 25 years to life plus one year. In 2019, he filed a petition for resentencing under section 1172.6, which was denied by the trial court after an evidentiary hearing.The California Court of Appeal, First Appellate District, reviewed the case. The court found that the trial court erred in denying the resentencing petition based on findings that Lopez-Barraza participated in planning and preparing for the robbery, which conflicted with the jury's acquittal on the conspiracy charge. The appellate court held that the trial court's reliance on these findings was improper and remanded the case for a new evidentiary hearing. The trial court was instructed not to rely on any evidence that contradicted the jury's verdict acquitting Lopez-Barraza of conspiracy. The order denying the petition was reversed, and the case was remanded for further proceedings consistent with the appellate court's opinion. View "P. v. Lopez-Barraza" on Justia Law

In 1987, John Bejarano shot and killed Roland Wright, a cab driver, during a robbery. Bejarano was convicted of first-degree murder, robbery, and other felonies. During the penalty phase, Bejarano made threatening statements to the jury, which contributed to his death sentence. The Nevada Supreme Court dismissed his direct appeal and Bejarano filed several unsuccessful post-conviction petitions in state and federal courts.The United States District Court for the District of Nevada denied Bejarano’s habeas corpus petition. Bejarano argued that the district court wrongly denied him an evidentiary hearing and that his trial counsel was ineffective for not presenting additional mitigation evidence. The district court found that Bejarano failed to exercise due diligence in developing the factual basis for his claims and denied the evidentiary hearing. It also concluded that even if trial counsel’s performance was deficient, Bejarano was not prejudiced.The United States Court of Appeals for the Ninth Circuit reviewed the case and affirmed the district court’s decision. The court held that Bejarano was not diligent in presenting his evidence in state court, and thus, the district court did not abuse its discretion in denying an evidentiary hearing. The court also found that Bejarano’s trial counsel’s performance was not deficient and that Bejarano was not prejudiced by any alleged deficiencies. Additionally, the court concluded that the Nevada Supreme Court provided appropriate appellate scrutiny of Bejarano’s death sentence.The Ninth Circuit denied Bejarano’s request for a certificate of appealability on three other issues, as he did not make a substantial showing of the denial of a constitutional right. The court ultimately affirmed the district court’s denial of Bejarano’s habeas corpus petition. View "Bejarano v. Reubart" on Justia Law

Theodore Singleton was stopped by a state trooper on Interstate 80 in Nebraska in December 2021. The trooper, Sutton, observed Singleton reduce his speed and momentarily cross the center line. Upon approaching the vehicle, Sutton smelled marijuana, leading to a search that uncovered drugs and a handgun. Singleton was charged with drug trafficking and firearms offenses and moved to suppress the evidence obtained during the stop.The United States District Court for the District of Nebraska, adopting the recommendation of a magistrate judge, denied Singleton's motion to suppress. The court found that Sutton had probable cause to stop Singleton for a traffic violation and to search the vehicle based on the odor of marijuana. Singleton entered a conditional guilty plea and was sentenced to 100 months in prison.The United States Court of Appeals for the Eighth Circuit reviewed the case. Singleton argued that the trooper lacked probable cause for the traffic stop and that the search was unjustified. The appellate court upheld the district court's findings, noting that the district court's credibility determinations were not clearly erroneous. The court concluded that Sutton had a reasonable belief that Singleton violated Nebraska law by crossing the center line and that the odor of marijuana provided probable cause for the search. The Eighth Circuit affirmed the district court's judgment, denying Singleton's motion to suppress the evidence. View "United States v. Singleton" on Justia Law

In early 2020, the Sioux Falls Police Department began investigating Robin and Lanny Vensand for methamphetamine distribution. Surveillance and traffic stops led to drug seizures, and a search of their residence yielded 844 grams of methamphetamine and $27,000 in cash. The investigation expanded with the DEA's involvement, revealing that Salvador Madrigal Jr. orchestrated a drug transportation network from California to South Dakota, employing couriers like William Hartwick and Maria Magana-Zavala. Madrigal's wife, Anahi Cardona, assisted in coordinating logistics. The operation also involved money laundering activities, with Madrigal, Cardona, and Madrigal's mother structuring bank deposits to avoid federal reporting requirements.The United States District Court for the District of South Dakota convicted Madrigal and Cardona of conspiracy to distribute methamphetamine and conspiracy to commit money laundering. Madrigal was sentenced to 400 months for methamphetamine distribution and 240 months for money laundering, to be served concurrently. Cardona was sentenced to 265 months for methamphetamine distribution and 240 months for money laundering, also to be served concurrently. Cardona's requests for safety-valve relief and challenges to the drug quantity attributed to her were denied.The United States Court of Appeals for the Eighth Circuit reviewed the case. Madrigal challenged the sufficiency of the evidence, arguing coercion by the cartel, but the court found ample evidence supporting his convictions. Cardona also challenged the sufficiency of the evidence, the admission of hearsay testimony, the drug quantity attributed to her, the denial of safety-valve relief, and claimed an unwarranted sentencing disparity. The court found sufficient evidence of her involvement in the methamphetamine conspiracy, upheld the admission of testimony as statements made in furtherance of the conspiracy, and found no error in the drug quantity determination or the denial of safety-valve relief. The court also found no abuse of discretion in her sentencing. The convictions and sentences were affirmed. View "United States v. Madrigal" on Justia Law

The defendant, Stacey Vaillancourt, operated a daycare facility in her home. In January 2019, six-month-old H.B. was dropped off at the daycare. On January 24, 2019, H.B. was found unresponsive in her crib and later declared dead at the hospital. An autopsy revealed that H.B. died from diphenhydramine intoxication, a substance found in medications like Benadryl, which is not recommended for infants without a prescription. H.B. had not been prescribed diphenhydramine, and her parents and other caregivers denied giving it to her.The Superior Court, Rutland Unit, Criminal Division, denied the defendant's motion for judgment of acquittal, and the jury found her guilty of involuntary manslaughter and cruelty to a child with death resulting. The defendant renewed her motion for judgment of acquittal, which was again denied by the trial court.The Vermont Supreme Court reviewed the case and affirmed the lower court's decision. The court held that there was sufficient evidence to support the jury's verdicts. The evidence showed that the defendant, an experienced childcare provider, administered diphenhydramine to H.B., leading to her death. The court found that the jury could reasonably infer that the defendant acted with criminal negligence and willfully exposed H.B. to danger, knowing the risks involved.The court also rejected the defendant's arguments that the verdicts were inconsistent and violated double jeopardy. The court explained that the mental states required for the two charges were not mutually exclusive and that the legislature intended to allow multiple punishments for the same conduct under different statutes. Finally, the court found no abuse of discretion in the trial court's admission of video evidence showing H.B.'s developmental capacity, as it was relevant to the State's case and not unduly prejudicial. View "State v. Vaillancourt" on Justia Law

The case involves the defendant, Amadeus Demetrius McClain, who was stopped by Iowa State Patrol troopers for speeding. During the stop, the trooper smelled marijuana and conducted a warrantless search of the vehicle, finding marijuana in a backpack in the trunk. McClain was charged with possession of marijuana with intent to deliver and failure to affix a drug tax stamp. He filed a motion to suppress the evidence, arguing the search was unconstitutional.The Iowa District Court for Buchanan County denied McClain's motion to suppress, finding that the trooper had probable cause to search the vehicle based on the smell of marijuana and that the automobile exception to the warrant requirement applied. McClain entered a conditional guilty plea, reserving the right to appeal the suppression ruling.The Iowa Supreme Court reviewed the case. The court first determined that it had jurisdiction to hear McClain's appeal in the interest of justice, despite the State's argument that McClain was raising new, unpreserved arguments on appeal. The court then addressed McClain's argument that the State failed to show the trooper's training to identify the odor of marijuana, concluding that McClain had not preserved this issue for appeal.Finally, the court considered McClain's argument to abandon the automobile exception to the warrant requirement. The court reaffirmed its previous decision in State v. Storm, which upheld the automobile exception, noting that the justifications for the exception, including the inherent mobility of vehicles and the lower expectation of privacy in vehicles, remain valid. The court concluded that the availability of electronic search warrants does not undermine the rationale for the automobile exception.The Iowa Supreme Court affirmed the district court's ruling denying McClain's motion to suppress and upheld his conviction. View "State of Iowa v. Mcclain" on Justia Law

An inmate, Trever Ballheim, appealed the denial of his petition for a writ of habeas corpus by the district court. Ballheim was originally sentenced to two different terms: 2 to 2 years for possession of a controlled substance and 10 to 11 years for being a habitual criminal. The district court later issued an order nunc pro tunc, changing the sentence for possession to 10 to 11 years, which Ballheim argued was void as it was issued without his presence and beyond the court's term.The district court dismissed Ballheim's petition without a hearing, citing that habeas corpus is not available for mere errors in judgment. Ballheim contended that the nunc pro tunc order was a nullity and that his sentence for being a habitual criminal was void, as it is not a crime. He argued that he had already served the valid sentence for possession.The Nebraska Supreme Court reviewed the case de novo and found that the nunc pro tunc order was void because it improperly changed the original sentence beyond correcting a clerical error. The court held that the original sentence for being a habitual criminal was void, as habitual criminality is not a separate crime but an enhancement. Since Ballheim had served the valid sentence for possession, he was entitled to habeas relief.The court reversed the district court's decision and remanded the case with directions to issue the writ of habeas corpus and hold a hearing to determine if Ballheim should be discharged from custody. View "Ballheim v. Settles" on Justia Law