Justia Criminal Law Opinion Summaries

On December 21, 2022, Oklahoma City Police officers received a tip that Karen Gonzalez, who had an outstanding arrest warrant, was at a Days Inn. Officers surveilled the area and followed a car they believed she entered to a gas station. They confirmed her identity and arrested her. Jonas Tyler, who was near the car, was detained, handcuffed, and placed in a police car. Despite his compliance and lack of suspicion, officers detained him further while waiting for a K-9 unit, which eventually led to the discovery of a firearm and drugs in his car.The United States District Court for the Western District of Oklahoma denied Mr. Tyler's motion to suppress the evidence found in his car, ruling that his continued detention was reasonable. Mr. Tyler then entered a conditional guilty plea to possession of a firearm by a previously convicted felon, reserving his right to appeal the suppression ruling. He was sentenced to 84 months in prison.The United States Court of Appeals for the Tenth Circuit reviewed the case and found that Mr. Tyler's continued detention after the arrest of Ms. Gonzalez was unreasonable and violated his Fourth Amendment rights. The court held that the government did not have a sufficient justification for detaining Mr. Tyler beyond the initial arrest of Ms. Gonzalez, as there was no reasonable suspicion of wrongdoing or dangerousness on his part. Consequently, the court vacated Mr. Tyler's conviction and sentence and remanded the case for further proceedings consistent with their opinion. View "United States v. Tyler" on Justia Law

The case involves the Attorney General's request to empanel a special grand jury to investigate allegations of sexual abuse by clergy within the Catholic Church in New Jersey. The Diocese of Camden challenged the grand jury's authority to issue a presentment on this subject, arguing that such a presentment would not relate to public affairs or conditions as required by law.The trial court denied the Attorney General's request to empanel a special grand jury and found that the anticipated presentment was not authorized by law. The court cited the substantial commitment of time and resources needed to select unbiased grand jurors, the financial hardship on jurors, and the fact that priests are not public officials and the Catholic Church is not a public entity. The court also noted that the presentment would be fundamentally unfair to those accused, as they would not have the same protections as defendants charged by indictment. The Appellate Division summarily affirmed the trial court's judgment.The Supreme Court of New Jersey reviewed the case and reversed the lower courts' decisions. The Court held that it was premature for the trial court to conclude that any potential presentment had to be suppressed, as no grand jury had completed an investigation or issued a presentment. The Court emphasized that the relevant case law and court rule on presentments contemplate the existence of both a grand jury investigation and an actual presentment for an assignment judge to review. The Court found that the State has the right to proceed with its investigation and present evidence before a special grand jury. If the grand jury issues a presentment, the assignment judge should review the report and publish it if it complies with the legal standards outlined by the Court. The Court vacated the trial court's analysis and remanded the matter for further proceedings consistent with its opinion. View "In re the Matter Concerning the State Grand Jury" on Justia Law

Fourteen plaintiffs, including pilots, a physician, a nurse, and an attorney, were required to undergo alcohol testing to maintain their employment and professional licenses. The tests, developed by United States Drug Testing Laboratories, Inc. (USDTL), indicated positive results for alcohol consumption, leading to significant professional harm. The plaintiffs alleged that the tests were unreliable and sued USDTL and its officers under the Racketeer Influenced and Corrupt Organizations Act (RICO) and state law. They also sued Choice Labs Services (CLS) and its owners, who provided the tests to the administrators.The plaintiffs initially filed suit in the Southern District of Florida, asserting claims for fraud and negligence. The district court dismissed the case without prejudice, finding the complaint insufficient. The plaintiffs then filed a second amended complaint, adding CLS as defendants. The case was transferred to the Northern District of Illinois, where the district court dismissed the RICO claims under Rule 12(b)(6) and denied supplemental jurisdiction over the state law claims. The plaintiffs' motion to alter or amend the judgment was also denied.The United States Court of Appeals for the Seventh Circuit reviewed the case de novo and affirmed the district court's decision. The court held that the plaintiffs failed to establish proximate causation for their RICO claims, as they did not adequately allege a direct link between USDTL's alleged misrepresentations and their professional injuries. The court also found that the plaintiffs did not meet the heightened pleading requirements for fraud under Rule 9(b). Consequently, the RICO claims were dismissed with prejudice, and the state law claims were dismissed without prejudice. View "Ratfield v United States Drug Testing Laboratories, Inc." on Justia Law

A 15-year-old girl, S.W., left her home in Anoka County, Minnesota, without permission to stay with her mother’s cousin, A.G., in Wisconsin, where A.G. lived with the defendant, Paulson. After using methamphetamine together, Paulson assaulted A.G., took S.W. to his family’s property in Stacy, Minnesota, and kept her there for two days, during which he threatened her, provided her with drugs, and sexually assaulted her. S.W. was eventually recovered in Anoka County, where she reported the kidnapping and assaults to police.Paulson was initially charged in Anoka County District Court with first- and second-degree criminal sexual conduct. He moved to dismiss, arguing the offenses occurred in Isanti County, not Anoka County. The district court denied the motion, finding venue proper in Anoka County under Minnesota Statutes section 627.15, since S.W. was found there. The State later amended the complaint to add a kidnapping charge, to which Paulson entered an Alford plea. He did not challenge venue for the new charge. The district court accepted the plea and imposed sentence. On appeal, Paulson argued that his plea was invalid because the factual basis did not establish that venue was proper in Anoka County as required by Minnesota Statutes section 627.01. The Minnesota Court of Appeals rejected this argument, holding that venue is not an element of the offense.The Minnesota Supreme Court reviewed whether the statutory venue requirement is an element of the offense for purposes of the accuracy requirement of a guilty plea. The court held that the venue requirement in section 627.01 is not an element of the offense, and therefore, the factual basis for Paulson’s guilty plea was sufficient even though it did not establish venue. The decision of the court of appeals was affirmed. View "State of Minnesota vs. Paulson" on Justia Law

Terry Eugene Ross Jr. was charged with multiple crimes, including domestic violence against his wife A.R., sexual abuse of his stepdaughters H.L. and D.L., and violations of protection orders. The incidents occurred between January and August 2019, with Ross allegedly exerting control and committing acts of violence and sexual abuse within the household. The State of Kansas consolidated five separate cases against Ross for trial, arguing that the crimes were part of a common scheme or plan to dominate and control the women in his household.The Sedgwick District Court granted the State's motion to consolidate the cases, finding that the crimes were of the same or similar character and part of a common scheme or plan. The court also ruled that the probative value of consolidating the cases outweighed any potential prejudice to Ross. Ross was convicted on most charges, but acquitted on a few, including aggravated assault and unlawful discharge of a firearm. He was sentenced to three consecutive life sentences plus additional time for other charges.The Kansas Court of Appeals reversed Ross' convictions, finding errors in the district court's decision to consolidate the cases and identifying prosecutorial error. The panel also concluded that the jury's convictions on two alternatively charged counts warranted reversal. The State petitioned for review, and Ross conditionally cross-petitioned.The Kansas Supreme Court held that the district court did not err in consolidating the cases, as the crimes were part of a common scheme or plan. The court also found no prosecutorial error in the opening statements and concluded that Ross failed to preserve a challenge to the inadvertent publication of an unredacted 911 call. The cumulative error doctrine did not apply as no errors were found. The Supreme Court reversed the Court of Appeals' decision, except for the two convictions on counts two and three of 19-CR-2036, which were left undisturbed and remanded for further proceedings. View "State v. Ross " on Justia Law

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