Justia Criminal Law Opinion Summaries

In July 2015, Jerome Diggs was fatally shot multiple times. Before dying, Diggs identified Gary Proctor as the shooter in calls and statements to bystanders. Witnesses placed Proctor near the scene, and forensic evidence linked ammunition found in Proctor’s room to the murder weapon. Security footage showed Proctor exchanging his phone, which contained incriminating photos, the day after the murder. Investigators uncovered possible motives, including a drug debt, a dispute over drug sales, and Diggs’s anticipated testimony at a civil protection order (CPO) hearing involving Proctor’s family.The government charged Proctor with first-degree premeditated murder while armed and related firearm offenses in the Superior Court of the District of Columbia. The trial court made several pretrial evidentiary rulings, including admitting Diggs’s statements about Proctor’s attempt to prevent his CPO testimony under the forfeiture-by-wrongdoing doctrine. During trial, Proctor moved for mistrial multiple times, citing references to his prior incarceration and alleged prosecutorial misconduct in closing argument. The trial court denied these motions, issued curative instructions, and ultimately the jury convicted Proctor on all counts. At sentencing, the court took judicial notice of Proctor’s prior murder conviction, allowing a life sentence without release.On appeal to the District of Columbia Court of Appeals, Proctor challenged the sufficiency of the evidence, the denial of mistrial motions, evidentiary rulings, and sentencing procedures. The Court of Appeals affirmed all convictions, holding that the evidence was sufficient, the trial court did not abuse its discretion in denying mistrial or admitting evidence, and sentencing procedures were proper. The court declined to address ineffective assistance of counsel claims on direct appeal, granting Proctor thirty days to file a motion under D.C. Code § 23-110 to develop the record on those claims. View "Proctor v. United States" on Justia Law

In this case, the defendant, a lawyer, was accused of delivering sixty-one orange strips containing Suboxone, a controlled substance, to an inmate at a county house of correction. The delivery was disguised as legal paperwork following instructions from another inmate. The strips were confiscated by officers who suspected they were Suboxone. Forensic testing was performed by analyst Dunlap, who concluded the strips contained Suboxone. Dunlap documented her procedures and results in her notes, but was no longer employed at the crime lab at the time of trial. Instead, LaBelle, a supervisor who had not participated in or observed the testing, reviewed Dunlap’s work and testified as a substitute expert, relaying Dunlap’s notes and offering her own opinion based on the case file.A jury in the Massachusetts Superior Court found the defendant guilty of unlawfully delivering a class B controlled substance to a prisoner. The Appeals Court affirmed the conviction, reasoning that LaBelle’s opinion was independent. After the United States Supreme Court decided Smith v. Arizona, the Supreme Court granted certiorari, vacated the Appeals Court’s judgment, and remanded for reconsideration in light of Smith. The Supreme Judicial Court of Massachusetts then transferred the case for review.The Supreme Judicial Court of Massachusetts held that the admission of LaBelle’s testimony violated the defendant’s Sixth Amendment right to confront witnesses. The Court found that LaBelle’s opinion was not independent, as it depended on the truth of Dunlap’s testimonial hearsay statements regarding the procedures and results of the testing. The Court concluded that this error was not harmless beyond a reasonable doubt and vacated the conviction, remanding for a new trial. The Court also held that its new rule applies prospectively to cases not yet final. View "Commonwealth v. Gordon" on Justia Law

Police officers in Kona, Hawai‘i, stopped a car for expired registration with Charles Zuffante as a passenger and his girlfriend as the driver. During the stop, officers observed a glass pipe and subsequently arrested both individuals. A search of Zuffante revealed 3.5 grams of methamphetamine, and a later search of the car uncovered an additional 130 grams of methamphetamine in various containers. The officers recorded the stop with body-worn cameras. The following day, a detective interrogated Zuffante in the Kona police station, where Zuffante signed a waiver of rights. Although the interrogation room was equipped for video recording, no recording was made due to claimed equipment failure. The detective did not take notes and later wrote a report summarizing Zuffante’s statements.Zuffante moved in limine in the Circuit Court of the Third Circuit to exclude the detective’s testimony about the unrecorded interrogation, arguing that admitting such testimony violated his constitutional rights and urging the court to adopt the recording requirement from Stephan v. State, as rejected in State v. Kekona. The circuit court denied the motion, and at trial, the detective testified that Zuffante confessed to possessing all the methamphetamine. Zuffante testified in his own defense, denying the confession. The jury convicted Zuffante of multiple drug offenses, and he was sentenced to twenty years in prison. On appeal, the Intermediate Court of Appeals (ICA) affirmed the conviction.The Supreme Court of the State of Hawai‘i reviewed the case and held that the Hawai‘i Constitution’s due process clause requires law enforcement to record all in-station custodial interrogations and, when feasible, all outside-the-station custodial interrogations. The court overruled State v. Kekona and established that failure to record, absent a showing of infeasibility, results in exclusion of the unrecorded statement. The court vacated the ICA’s judgment and the circuit court’s conviction, remanding for further proceedings. View "State v. Zuffante" on Justia Law

A defendant was indicted for two counts involving sexual acts with a minor under fourteen. Before trial, the prosecution filed a bill of particulars specifying the acts alleged to support the charges, including statutory definitions of “sexual contact” and “sexual penetration.” At trial, the minor testified to multiple incidents of sexual contact and penetration over several years, as well as a specific incident in July 2019. The trial court, after acquitting the defendant of the most serious charge, submitted lesser included offenses to the jury and provided jury instructions that used modified statutory definitions, omitting terms not relevant to the evidence. The jury convicted the defendant of Attempted Sexual Assault in the First Degree and Continuous Sexual Assault of a Minor Under Fourteen.The defendant appealed to the Intermediate Court of Appeals, arguing that the jury instructions were erroneous because they allowed conviction for conduct outside the specific acts listed in the bill of particulars. The appellate court agreed, finding that the omission of the bill’s specific acts from the instructions, combined with the broader statutory definitions, may have contributed to the convictions. The appellate court vacated the convictions and remanded for a new trial.The Supreme Court of the State of Hawai‘i reviewed the case. It held that while a bill of particulars limits the evidence the prosecution may present at trial, it does not similarly restrict the content of jury instructions. The court found that the omission of the specific acts from the jury instructions was not erroneous and that there was no reasonable possibility any instructional error contributed to the convictions. The Supreme Court reversed the appellate court’s judgment and affirmed the trial court’s judgment of conviction and sentence. View "State v. Masuda-Mercado" on Justia Law

A defendant was charged with second-degree murder after his elderly, wheelchair-bound landlord was found dead with multiple stab wounds. The prosecution presented extensive physical and circumstantial evidence, including DNA linking the defendant to the crime scene and the victim, as well as testimony about the defendant’s motive related to an eviction order. The defendant testified in his own defense, offering alternative explanations for the physical evidence.During jury selection in the Circuit Court of the Fifth Circuit, a prospective juror made comments in the courthouse hallway expressing a desire to be excused, stating she “already had [her] opinion” and making remarks about the defendant’s appearance and discomfort with the case. The court questioned the prospective juror and three others who overheard the comments. The prospective juror was excused, and the court issued curative instructions to the remaining jury pool. The three other prospective jurors were not empaneled or selected as alternates. The defense moved for a mistrial, arguing the comments tainted the jury, but the motion was denied.On appeal, the Intermediate Court of Appeals vacated the conviction, finding the trial court’s inquiry into the comments insufficient and the curative instructions inadequate. The State sought review.The Supreme Court of the State of Hawai‘i held that the trial court’s investigation into the comments was adequate, its curative instructions were sufficient to cure any potential prejudice, and any prejudice was harmless beyond a reasonable doubt given the overwhelming evidence of guilt. The court concluded there was no abuse of discretion in denying the mistrial motion, reversed the Intermediate Court of Appeals’ judgment, and affirmed the conviction and sentence. View "State v. Grewer" on Justia Law

In the early morning hours, police responded to a 911 call from a woman who reported that her boyfriend, Shaquan Coffer, had damaged her car and was armed. Officers located the vehicle, separated the two individuals, and learned from the woman that Coffer was intoxicated and carrying a firearm. While speaking with an officer, Coffer attempted to conceal something in his waistband and then fled on foot. During the chase, officers saw him reach into his pants and heard a metallic sound; they recovered a loaded handgun, painted white, from the ground 11 seconds later. Coffer was apprehended shortly after.Following Coffer’s guilty plea to being a felon in possession of a firearm, the United States District Court for the Northern District of Iowa considered whether to apply a two-level sentencing enhancement for recklessly creating a substantial risk of death or serious bodily injury during flight from law enforcement under U.S.S.G. § 3C1.2. The Presentence Investigation Report did not recommend the enhancement, but the government objected. At sentencing, the district court found that, although accidental discharge was unlikely due to the firearm’s safety features, discarding a loaded gun in public created a substantial risk to others, particularly because of the gun’s appearance. The court applied the enhancement, increasing Coffer’s guideline range, and imposed a 71-month sentence.The United States Court of Appeals for the Eighth Circuit reviewed the case. It held that the district court erred in applying the enhancement, as the government failed to show that Coffer’s conduct created more than a speculative risk of harm; there was no evidence of bystanders or actual endangerment beyond the mere act of discarding the firearm. The appellate court vacated Coffer’s sentence and remanded for resentencing, finding the error in guideline calculation was not harmless. View "United States v. Coffer" on Justia Law

The defendant was convicted of murder with special circumstances, home invasion, arson in the second degree, and robbery in the first degree, following a violent home invasion in Griswold, Connecticut. The crimes involved the planned theft of a gun safe and guns from the Lindquist family home, orchestrated with the help of the victims’ son, Matthew, who was later killed by the defendant and his sister, Ruth. After killing Matthew in a nearby wooded area, the defendant and Ruth entered the Lindquist home, killed Kenneth and Janet Lindquist, stole various items, and set the house on fire. The defendant’s cell phone was seized by police without a warrant after an interview, and a subsequent warrant authorized the search and seizure of “all data” from the phone, without any temporal limitations.In the Superior Court for the judicial district of New London, the defendant moved to suppress evidence obtained from his cell phone, arguing the seizure was illegal and the warrant was unconstitutional due to its broad scope. The trial court found the seizure proper and, applying the severance doctrine, limited admissible evidence to data created or received within a two-week period surrounding the crimes, suppressing data outside that window. The jury convicted the defendant on most counts, and the court vacated certain convictions before sentencing him to life imprisonment without parole.On appeal to the Connecticut Supreme Court, the defendant challenged the constitutionality of the cell phone search warrant. The Supreme Court assumed, without deciding, that the warrantless seizure was constitutional, but held that the warrant violated the Fourth Amendment’s particularity requirement because it authorized a search of all data without content or time limits. The Court further found the trial court erred in applying the severance doctrine to cure the warrant’s deficiencies. Nevertheless, the Supreme Court concluded that the error was harmless beyond a reasonable doubt, as the cell phone evidence was cumulative and the state’s case was strong without it. The judgment of conviction was affirmed. View "State v. Correa" on Justia Law

Celia Ignacia Esquivel-Bataz, a Mexican citizen, was previously convicted of making a false statement to obtain credit and deported in 2012. In April 2025, she was found by ICE agents at an illegal gambling parlor in Houston. She was indicted for illegal reentry after deportation following a felony conviction, in violation of 8 U.S.C. § 1326(a) and (b). ICE lodged an immigration detainer against her, indicating that she would be taken into custody and removed to Mexico if released.A magistrate judge initially found that Esquivel-Bataz was not a flight risk and ordered her release on bond pending trial. The Government responded with an emergency motion to stay and revoke the release order, which the United States District Court for the Southern District of Texas granted. Esquivel-Bataz then moved for pretrial release, and the district court held an evidentiary hearing. After hearing testimony, including from an ICE officer about the detainer’s effect, the district court denied her motion, finding her to be a flight risk based on her criminal history, Mexican citizenship, prior deportation, and current unlawful presence.On appeal, the United States Court of Appeals for the Fifth Circuit reviewed the district court’s order under an abuse-of-discretion standard. The appellate court held that the district court did not abuse its discretion in denying pretrial release. The Fifth Circuit clarified that the district court did not treat the immigration detainer or potential deportation as flight risk per se, but rather considered the totality of circumstances, including individualized factors required by the Bail Reform Act. The order denying pretrial release was affirmed. View "United States v. Esquivel-Bataz" on Justia Law

The case concerns the fatal shooting of Brett Ness in Billings, Montana, following a series of drug-related disputes. Alexander Garrett LaForge III, along with several others, was involved in confrontations with Ness over an alleged shortfall in a methamphetamine transaction. After escalating tensions and threats, LaForge and a group of associates returned to Ness’s trailer, where LaForge shot Ness in the head with a .45 caliber pistol. Ness died later that day. Multiple co-defendants received plea deals in exchange for their testimony against LaForge.The Thirteenth Judicial District Court, Yellowstone County, presided over LaForge’s trial. LaForge requested a substitution of counsel shortly before trial, citing communication issues and dissatisfaction with his attorney’s preparation. The District Court conducted an inquiry and denied the request, finding no substantial breakdown in communication. During trial, LaForge also requested a cautionary jury instruction regarding the credibility of co-defendants’ testimony, which the District Court declined, instead providing standard witness credibility instructions and a specific instruction regarding one co-defendant’s accountability. The jury convicted LaForge of deliberate homicide. At sentencing, the court ordered LaForge to pay $72,000 in restitution to the victim’s mother for lost business income, based on her testimony about canceled jobs following her son’s death.The Supreme Court of the State of Montana reviewed the case. It held that the District Court did not abuse its discretion in denying LaForge’s request for substitute counsel or in its jury instructions regarding co-defendant testimony. However, the Supreme Court found that the $72,000 restitution award was not supported by sufficient evidence and that the record was unclear as to whether the victim’s mother, as a business representative, qualified as a “victim” under the restitution statutes. The Supreme Court affirmed the conviction and other aspects of the judgment, reversed the restitution award, and remanded for a new hearing to determine the proper amount and recipient of restitution. View "State v. LaForge" on Justia Law

Over a period of 35 years, the defendant operated a dogfighting enterprise known as Stone City Kennel, where he bred, trained, and sold dogs for fighting, mentored others in the practice, and participated in over 150 dogfights across the Americas and the Caribbean. He was known as a prominent figure in the dogfighting world. After admitting incriminating information to an undercover agent, he was indicted in the District of Puerto Rico for conspiracy to violate the Animal Welfare Act (AWA) and for possession of dogs for use in animal fighting. A search of his property revealed four dogs in poor condition, leading to a superseding indictment with additional possession counts. He ultimately pleaded guilty to one conspiracy count and two possession counts.The United States District Court for the District of Puerto Rico grouped the offenses and calculated a Sentencing Guidelines Range (GSR) of 12 to 18 months. However, the Presentence Investigation Report and the government argued for a much higher sentence, citing the exceptional scale and cruelty of the defendant’s conduct. At sentencing, the court heard expert testimony and considered the defendant’s extensive involvement, the cruelty involved, and the need for deterrence. The court imposed an 84-month sentence: 36 months for conspiracy and 24 months for each possession count, to be served consecutively, and described the sentence as an upward variance based on the statutory sentencing factors.On appeal, the United States Court of Appeals for the First Circuit reviewed the defendant’s challenges, including claims of double jeopardy, inadequate explanation, and substantive unreasonableness. The court held that consecutive sentences for conspiracy and possession did not violate double jeopardy, that the statutory text allowed separate punishment for each dog possessed, and that the district court adequately explained and justified the upwardly variant sentence. The First Circuit affirmed the judgment of the district court. View "United States v. Casillas-Montero" on Justia Law