Justia Criminal Law Opinion Summaries

The petitioner was indicted in Randolph County, West Virginia, on three charges: possession with intent to deliver a controlled substance (a felony), carrying a deadly weapon (a misdemeanor), and improper registration (a misdemeanor). To resolve these charges, the petitioner and the State entered into a plea agreement. Under its terms, the petitioner agreed to plead guilty to the drug and registration charges, while the State agreed to dismiss the deadly weapon charge. Importantly, prosecution of the drug charge was deferred for twenty-four months under a pretrial diversion agreement; if the petitioner successfully completed the diversionary period and complied with all conditions, the drug charge would be dismissed. The petitioner did so, and the circuit court dismissed the drug charge with prejudice.Afterward, the petitioner sought to expunge all records related to the dismissed drug charge under West Virginia Code § 61-11-25(a) (2012). The Circuit Court of Randolph County denied the petition, finding that the drug charge was dismissed in exchange for a guilty plea to another offense, making the petitioner ineligible for expungement under the statute. The petitioner appealed to the Intermediate Court of Appeals of West Virginia, which affirmed the circuit court’s decision, concluding that the dismissal of the drug charge was part of the same exchange as the guilty plea and thus barred expungement.On further appeal, the Supreme Court of Appeals of West Virginia reviewed the case for abuse of discretion and interpreted the statute de novo. The court held that the plain language of West Virginia Code § 61-11-25(a) precludes expungement when a charge is dismissed in exchange for a guilty plea to another offense. The court affirmed the lower courts’ decisions, finding that the petitioner was ineligible to seek expungement of the drug charge under the applicable statute. View "In re: Petition of D.K. for Expungement of Record" on Justia Law

Kimberly Anderson was charged with three felonies after stabbing her boyfriend with a boxcutter and threatening to kill him. Before trial, she entered a plea agreement with the State, pleading guilty to two charges—felony domestic battery and felony intimidation. In exchange, the State dropped one charge, refrained from adding another, and agreed to a maximum executed sentence of four years, with the specific sentence left to the trial court’s discretion. The agreement included a provision in which Anderson waived her right to appeal any sentence imposed within the terms of the agreement.At the sentencing hearing in the Marion County Superior Court, the judge reviewed the plea agreement with Anderson, confirmed her understanding, and heard arguments from both sides regarding aggravating and mitigating factors. The court ultimately sentenced Anderson to three years executed and three years suspended to probation. After sentencing, the court mistakenly told Anderson she could appeal her sentence, prompting her to do so. Anderson’s appeal to the Indiana Court of Appeals argued that the trial court abused its discretion by considering improper factors and failing to recognize significant mitigating evidence. The State moved to dismiss the appeal based on the waiver, and a divided motions panel of the Court of Appeals dismissed the appeal. Anderson then sought transfer to the Indiana Supreme Court.The Indiana Supreme Court held that a sentence is “illegal”—and thus not subject to an appeal waiver—only if it is outside the statutory range or unconstitutional. Anderson’s sentence was within the statutory range and not unconstitutional; her arguments concerned alleged abuse of discretion, not illegality. The Court found the appeal waiver valid and comprehensive, and dismissed Anderson’s appeal. View "Kimberly R. Anderson v. State of Indiana" on Justia Law

In this case, the defendant was convicted of sex trafficking a minor after a jury trial. The evidence showed that in 2022, a 15-year-old girl ran away from home and met the defendant in Houston. The defendant, knowing her age, engaged in non-consensual sex with her, supplied her with drugs, and coerced her into sex work. He arranged for her to be photographed in lingerie for online advertisements and kept the money she earned from commercial sex acts, using it for personal expenses. The victim eventually escaped and was hospitalized, where she expressed severe emotional distress and suicidal thoughts. Her mother stayed with her during her hospital stay, incurring lost wages and later purchasing clothing to help her daughter feel safer in public.The United States District Court for the Southern District of Texas presided over the trial and sentencing. The jury found the defendant guilty, including findings that the victim was under eighteen and that force, threats, fraud, or coercion were involved. The presentence report calculated a Guidelines range of life imprisonment, but the district court imposed a sentence of 480 months’ imprisonment and ten years of supervised release, and later ordered restitution, including amounts for the mother’s lost wages and clothing purchases. The defendant objected to these restitution components and to the consideration of certain statements in the victim-impact statement, and also identified a clerical error in the written judgment.The United States Court of Appeals for the Fifth Circuit reviewed the case. It held that the district court did not plainly err in considering the full victim-impact statement, did not exceed its statutory authority in awarding restitution for the mother’s lost wages and clothing purchases, and that the statutory scheme allowed such restitution as proximate results of the offense. The Fifth Circuit affirmed the sentence and restitution order, but remanded for correction of the clerical error in the amended judgment to match the court’s oral pronouncement. View "USA v. Limon" on Justia Law

Police searched Franklin James’s apartment and found illegal drugs, drug paraphernalia, and firearms. The State charged him with eleven counts related to these items. James entered a plea agreement, pleading guilty to three counts in exchange for the dismissal of the remaining charges. Both parties agreed to recommend probation so James could receive drug treatment, and James wrote letters to the court expressing remorse. At sentencing, the district court rejected the probation recommendation, citing James’s criminal history and stating that treatment would be available in prison. The court sentenced James to prison and did not invite him to speak before sentencing, nor did James request to do so.James appealed to the Utah Court of Appeals, arguing that the district court violated his constitutional and statutory right to allocution by not allowing him to address the court before sentencing. He also claimed the court abused its discretion by disregarding the unanimous recommendation for probation. The court of appeals found that the failure to invite allocution was plain error and, following the Tenth Circuit’s approach in United States v. Bustamante-Conchas, held that James demonstrated prejudice simply by showing the denial of his right to allocute. The court vacated his sentence and did not reach the abuse-of-discretion claim.The Supreme Court of the State of Utah reviewed the case and reversed the court of appeals. It declined to adopt the Tenth Circuit’s rule that allocution error alone demonstrates prejudice in Utah’s sentencing regime, which differs from the federal system. The court held that, in Utah, a defendant must show case-specific prejudice from denial of allocution, and James failed to do so. The case was remanded for the court of appeals to consider James’s remaining claim regarding abuse of discretion in sentencing. View "State v. James" on Justia Law

A man was charged with murder after fatally shooting another individual in a restaurant. The defendant admitted to the shooting but claimed he acted in self-defense, believing the victim was reaching for a weapon, though the victim was unarmed. The incident followed a series of escalating personal disputes involving the defendant, his friend, and the victim. On the night of the shooting, the defendant and his companions sought out the victim at a restaurant, where a confrontation ensued, culminating in the shooting.The case was tried in the Third District Court, Salt Lake County. At trial, the defendant requested a jury instruction clarifying that actual danger is not required for self-defense—only the appearance of danger is necessary. The court declined to give this specific instruction, reasoning that the concept was already covered by the standard self-defense instructions. The defendant’s counsel was permitted to argue this point in closing. The jury convicted the defendant of murder and felony discharge of a firearm. The defendant appealed, arguing that the trial court erred in refusing his proposed instruction and that his counsel was ineffective for not objecting to witnesses referring to the decedent as “victim” and to the admission of an emotional 911 call.The Supreme Court of the State of Utah reviewed the case. It held that the district court did not abuse its discretion in refusing the defendant’s proposed jury instruction, as the instructions given adequately covered the law of self-defense. The court also found that the defendant did not receive ineffective assistance of counsel, as the use of the term “victim” by witnesses was not unreasonable in context, and the admission of the 911 call did not prejudice the outcome. The Supreme Court affirmed the convictions. View "State v. Hunt" on Justia Law

In 2001, Joseph Jackson, then twenty years old, was involved in a drug-related conflict in southeast Washington, D.C. After being told by a rival dealer, Larry Smith, that he could no longer sell drugs in the area, Jackson instructed his associate, Troy Ashley, to “handle that.” Ashley, with the help of Jason Parker, confronted Smith and his associates, resulting in Ashley shooting and killing Smith and robbing and shooting the other two men. Ashley and Parker reported back to Jackson, who expressed excitement and rewarded Parker with drugs. Jackson was subsequently convicted by a jury in 2003 of first-degree premeditated murder, armed robbery, and other offenses.The District of Columbia Court of Appeals previously affirmed Jackson’s convictions and remanded for merger of offenses and resentencing, after which Jackson received a thirty-five-year prison term. In 2023, Jackson moved in the Superior Court of the District of Columbia for a sentence reduction under the Incarceration Reduction Amendment Act (IRAA), arguing that he had matured and was no longer dangerous. The government opposed, citing Jackson’s extensive record of violent and nonviolent disciplinary infractions during incarceration, including assaults and possession of contraband. The Superior Court found Jackson met the threshold for IRAA consideration but, after reviewing the statutory factors, determined that his continued infractions and lack of rehabilitation weighed against sentence reduction. The court denied the motion, finding Jackson remained a danger and that the interests of justice did not warrant modification.The District of Columbia Court of Appeals reviewed the denial for abuse of discretion. The court held that the Superior Court properly considered the relevant IRAA factors, including Jackson’s personal circumstances and role in the offense, and found no error in its analysis. The appellate court affirmed the Superior Court’s order denying Jackson’s motion for sentence reduction. View "Jackson v. United States" on Justia Law

After being involved in a head-on collision during a snowstorm, the appellant was detained by police on suspicion of driving while impaired. Law enforcement obtained a search warrant authorizing a blood test, but not a urine test. The appellant refused to submit to both the blood test (for which there was a warrant) and a urine test (for which there was not). He was subsequently charged with first-degree test refusal. The appellant moved to suppress evidence of his refusals and to dismiss the charge, arguing that the statutes required refusal of both tests to sustain a conviction and that, because there was no warrant for a urine test, his prosecution violated the Fourth Amendment.The District Court denied the appellant’s motion, concluding that the relevant statutes did not require warrants for both blood and urine tests to prosecute for test refusal. The appellant waived his right to a jury trial, and the District Court found him guilty of first-degree test refusal based on stipulated facts. On appeal, the Minnesota Court of Appeals affirmed the conviction, holding that the statutory language required only refusal of the test authorized by the warrant and that there was no requirement for law enforcement to obtain warrants for both types of tests.The Minnesota Supreme Court reviewed the case and held that when a warrant authorizes only one type of chemical test—either blood or urine—a person’s refusal to submit to that specific test is sufficient for a conviction under Minn. Stat. §§ 169A.20, subd. 2(2), and 171.177, subd. 2. The Court further held that a conviction for refusing a warranted chemical test does not violate the Fourth Amendment. The decision of the Court of Appeals was affirmed, though on different grounds. View "State of Minnesota vs. Lueck" on Justia Law

The case concerns a defendant who, while driving under the influence of alcohol with a blood alcohol content of at least 0.18 percent, crashed into another vehicle, resulting in the deaths of three individuals and causing serious injury to a fourth person, Sarah S. The defendant was charged with multiple felonies, including three counts of gross vehicular manslaughter while intoxicated, two counts of driving under the influence causing injury to Sarah, and two counts of perjury. He pled no contest to the perjury charges and was found guilty by a jury on all remaining counts.Following his conviction in San Mateo County Superior Court, the defendant was originally sentenced to 47 years and two months to life in prison. On direct appeal, the California Court of Appeal ordered corrections to the abstract of judgment but otherwise affirmed the conviction. After remittitur and resentencing, the trial court imposed a sentence of 47 years to life. The defendant appealed again, arguing that his convictions for driving under the influence causing injury should be dismissed as lesser included offenses of gross vehicular manslaughter while intoxicated, and also challenged the trial court’s failure to specify the fines and fees imposed at resentencing.The California Court of Appeal, First Appellate District, Division Three, held that driving under the influence causing injury is not a lesser included offense of gross vehicular manslaughter while intoxicated when the offenses involve different victims. The court also found that the trial court erred by not itemizing the fines and fees imposed at resentencing. The appellate court remanded the matter for the trial court to specify the amount and statutory basis for each fine, fee, and assessment, but otherwise affirmed the judgment. View "People v. Demacedo" on Justia Law

Three men, including Andre Anthony, entered a Family Dollar Store in Hardin, Montana, and over about ten minutes, one of the men fraudulently completed three transactions at the computerized cash register by pressing the “cash received” button without providing payment. Surveillance video showed Anthony standing near the register, at times distracting the store attendant, while the fraudulent transactions occurred. The men left with three gift cards and a bottle of body wash, totaling $1,512.35. Law enforcement later detained the men and found receipts and merchandise matching the transactions in their vehicle. The store attendant misidentified Anthony as the man who pressed the register button, but Anthony was arrested and charged.Initially, Anthony was charged in Hardin City Court with shoplifting, but the charges were amended to unlawful use of a computer by accountability. After posting bail, Anthony returned to Michigan and requested to appear at hearings by video, which was sometimes permitted. At trial, Anthony appeared by video, but the court denied his request to testify by video after the prosecution rested. The City Court found Anthony guilty on all three counts. On appeal, the District Court for the Twenty-Second Judicial District affirmed the convictions and sentence, finding sufficient evidence and no reversible error in the denial of Anthony’s request to testify by video.The Supreme Court of the State of Montana reviewed the case de novo. It held that the evidence was sufficient to support Anthony’s convictions for unlawful use of a computer by accountability, as his actions and presence supported a finding that he aided or abetted the offenses. However, the Supreme Court found that the City Court abused its discretion by allowing Anthony to appear by video for trial but then denying his request to testify by video without clear explanation. The Supreme Court reversed Anthony’s convictions and remanded for a new trial on all counts. View "City of Hardin v. Anthony" on Justia Law

The case concerns an incident in which the defendant was accused of engaging in sexual intercourse without consent with the complainant, K.R., who had spent the afternoon and evening drinking at several bars. The two were acquaintances and exchanged messages on Facebook, with K.R. inviting the defendant to her home. K.R. later testified that she did not remember the events after leaving the bar, including her communications with the defendant, driving home, or leaving her door unlocked. She recalled regaining awareness during a sexual encounter at her home, at which point she told the man to stop. The defendant asserted that he did not know K.R. was unable to consent, pointing to her actions and communications as evidence that she appeared functional.The Second Judicial District Court of Montana presided over the trial. The court excluded evidence of K.R.’s past alcohol use and denied the defense’s request to present expert testimony on the effects of regular alcohol consumption. The court also instructed the jury that the defendant could be found guilty if he was aware of a “high probability” that K.R. was unable to consent, rather than requiring actual knowledge. The jury found the defendant guilty, and he was sentenced to twenty years in prison, with five years suspended.On appeal, the Supreme Court of the State of Montana reviewed whether the district court’s jury instruction on the mental state required for conviction and its exclusion of certain evidence constituted reversible error. The Supreme Court held that the district court erred by giving a result-based instruction for “knowingly,” which lowered the State’s burden of proof and violated the defendant’s due process rights. The court also found no abuse of discretion in excluding evidence of K.R.’s past drinking habits or the expert testimony as offered. The conviction was reversed and the case remanded for a new trial. View "State v. Pierce" on Justia Law