Justia Criminal Law Opinion Summaries

Police in Hawai‘i County obtained a search warrant to search an individual suspected of narcotics dealing. The suspect was stopped while driving his pickup truck, and officers executed the warrant, finding nothing on his person. After the search, an officer asked for consent to search the truck. Instead of giving a direct answer, the suspect made an incriminating statement indicating contraband was in the vehicle. He was not told he was free to leave or given Miranda warnings before this exchange. The truck was later searched under a separate warrant, and over an ounce of methamphetamine was found. The suspect was charged and, after a jury trial, convicted of Promoting a Dangerous Drug in the First Degree.The Circuit Court of the Third Circuit denied the defendant’s motions to suppress evidence and found his statements voluntary, admitting them at trial. The court also admitted expert testimony regarding the identity and weight of the drugs, over defense objections about the expert’s qualifications. The Intermediate Court of Appeals (ICA) vacated the conviction, holding that the State failed to lay a sufficient foundation for the expert’s qualifications because it did not show the expert was trained according to the manufacturers’ requirements for the testing devices. The ICA affirmed the circuit court on other issues.The Supreme Court of Hawai‘i reviewed the case. It held that the ICA erred in requiring the State to show the expert was trained in accordance with device manufacturers’ requirements. The proper standard is that the State must establish, by a preponderance of the evidence, the expert’s qualifications, use of valid techniques, and that the instruments were in proper working order. The court also held that the brief continued detention after the search was justified by reasonable suspicion, and that the initial incriminating statement was admissible. Any Miranda violation in subsequent questioning was harmless. The Supreme Court reversed the ICA’s judgment and affirmed the conviction. View "State v. Spies" on Justia Law

The defendant was charged with misdemeanor driving under the influence in Riverside County, California, and sought pretrial military diversion under Penal Code section 1001.80. He had served five months of active duty in the United States Marine Corps and several years in the reserves. The trial court denied his request, finding him ineligible because he had not completed at least one year of active service or one day of combat, relying on a local Memorandum of Understanding (MOU) and its interpretation of legislative intent.The defendant petitioned for a writ of mandate in the Appellate Division of the Riverside County Superior Court. The People conceded that Penal Code section 1001.80 does not require a minimum of one year of service. The Appellate Division agreed, holding that the statute contains no such time requirement and remanded for the trial court to reconsider eligibility. The Appellate Division also clarified that, even if eligible, a defendant is not automatically entitled to diversion; the trial court retains discretion to assess suitability for diversion, guided by the statute’s rehabilitative purpose.The California Court of Appeal, Fourth Appellate District, Division Two, then transferred the case for review. The court held that Penal Code section 1001.80 does not impose a minimum service duration for eligibility for military diversion, and the MOU’s one-year requirement does not apply to diversion under this statute. The court further held that trial courts must first determine eligibility under the statute and then exercise discretion to assess suitability for diversion, considering factors consistent with the statute’s rehabilitative goals. The court issued a writ directing the superior court to vacate its denial and conduct further proceedings consistent with these principles. View "Angulo v. Superior Court" on Justia Law

Two former employees of a large technology company, along with a real estate developer and related individuals and entities, were alleged to have engaged in a kickback scheme involving real estate transactions in Northern Virginia. The employees, responsible for managing real estate deals for the company, allegedly steered contracts to the developer’s firm in exchange for secret payments funneled through a network of trusts and entities. The scheme purportedly inflated the company’s costs for both leasing and purchasing properties, with millions of dollars in kickbacks distributed among the participants. The company discovered the scheme after a whistleblower report, conducted an internal investigation, and reported the matter to federal authorities.The United States District Court for the Eastern District of Virginia granted summary judgment in favor of the defendants on several claims, including those under the Racketeer Influenced and Corrupt Organizations (RICO) Act, fraud, unjust enrichment, and conversion, and partially on a civil conspiracy claim. The district court found that the company failed to establish the existence of a RICO enterprise, did not show injury to its business or property, and that equitable claims were precluded by the availability of legal remedies or the existence of contracts. The court also ruled that an attorney defendant could not be liable for conspiracy with his clients.The United States Court of Appeals for the Fourth Circuit reversed the district court’s summary judgment. The appellate court held that genuine disputes of material fact existed regarding the existence of a RICO enterprise, whether the company suffered financial harm, and the viability of the fraud, unjust enrichment, conversion, and civil conspiracy claims. The court clarified that the company was entitled to pursue legal and equitable remedies in the alternative and that the attorney’s potential liability for conspiracy could not be resolved on summary judgment. The case was remanded for further proceedings. View "Amazon.com, Inc. v. WDC Holdings LLC" on Justia Law

A man was convicted by a jury of aggravated sexual abuse of a minor under twelve years of age in Indian Country. The events leading to the charges occurred during his brief marriage to the child’s mother, when he often cared for her seven-year-old daughter while the mother worked night shifts. The child later disclosed the alleged abuse to family members, which was recorded and reported to authorities. During the investigation, law enforcement also received information suggesting the defendant may have abused other young girls, and three additional children testified at trial about similar conduct. The defendant denied all allegations and presented evidence of his good character, medical issues, and the nature of his relationship with the child and her mother.The United States District Court for the Northern District of Oklahoma denied the defendant’s pretrial motion to suppress statements made during a custodial interrogation, finding no coercion or involuntariness. At trial, the court admitted testimony from other alleged victims under Federal Rule of Evidence 414 and allowed certain statements by the defendant’s ex-wife. The court also gave a jury instruction stating that child witnesses are presumed competent and declined to instruct the jury that it must unanimously find, by a preponderance of the evidence, that the defendant committed the other alleged acts before considering them. The jury found the defendant guilty, and he was sentenced to life imprisonment.On appeal, the United States Court of Appeals for the Tenth Circuit reviewed the defendant’s claims of instructional and evidentiary error, the denial of his suppression motion, and the alleged cumulative effect of any errors. The court held that a jury need not unanimously find by a preponderance that a defendant committed Rule 414 acts before individual jurors may consider such evidence. The court found no reversible error in the evidentiary rulings, jury instructions, or suppression decision, and affirmed the conviction. View "United States v. Paycer" on Justia Law

Rajeri Curry was investigated for drug trafficking after purchasing heroin and fentanyl in bulk from two brothers, Al-Tariq and Shadee Brown. Following a fatal overdose linked to drugs Curry sold, police arrested her and seized her iPhone. After being read her Miranda rights, Curry requested a lawyer. Detectives then asked for consent to search her phone, explaining that refusal would lead to a warrant and possible data loss. Concerned about losing her files, Curry provided her passcode and signed a consent form. The detectives did not question her about the charged offenses during this interaction.Curry was indicted in the United States District Court for the District of New Jersey for conspiracy to distribute heroin and fentanyl, possession with intent to distribute, and distribution resulting in death. Before trial, she moved to suppress evidence obtained from her phone, arguing it was inadmissible due to a violation of the Edwards v. Arizona rule. The District Court denied the motion, admitted the evidence, and allowed the prosecution to introduce Curry’s prior drug convictions. After trial, the jury convicted Curry of conspiracy and possession with intent to distribute, but did not reach a verdict on the distribution resulting in death count. The District Court denied Curry’s motion for judgment of acquittal and sentenced her as a career offender to 216 months’ imprisonment.The United States Court of Appeals for the Third Circuit reviewed the case. The court held that evidence derived from Curry’s phone was not subject to suppression under Edwards v. Arizona because Curry voluntarily provided her passcode and consented to the search. The court affirmed the District Court’s judgment, finding no error in the denial of the suppression motion, the sufficiency of evidence for conspiracy, the admission of prior convictions under Rule 404(b), and the application of the career-offender sentencing enhancement. View "USA v. Curry" on Justia Law

A man was arrested after he attempted to meet someone he believed to be a 12-year-old girl for sex, following extensive online and text communications. The “girl” was actually a fictional persona created by law enforcement as part of an undercover operation. After his arrest, officers obtained a warrant to search his residence, where they discovered a large quantity of child pornography on a hard drive. The defendant was charged with attempted coercion and enticement of a minor to engage in illegal sexual activity, as well as possession of child pornography.The United States District Court for the District of Montana denied the defendant’s pretrial motions to suppress the evidence seized from his residence, to sever the two charges in the indictment, and to exclude evidence of his uncharged interactions with a 17-year-old girl. The court found that the search warrant was supported by probable cause, that the charges were properly joined as offenses of similar character, and that the evidence regarding the 17-year-old was admissible to show intent. After a jury convicted the defendant on both counts, the district court sentenced him to 154 months’ imprisonment on each count, to run concurrently.On appeal, the United States Court of Appeals for the Ninth Circuit affirmed the conviction and sentence. The court held that the search warrant was supported by probable cause to search for both enticement and child pornography, and that any omission in the warrant affidavit was immaterial. The court also held that the charges were properly joined under Federal Rule of Criminal Procedure 8(a), and that the evidence of the defendant’s relationship with the 17-year-old was properly admitted under Federal Rules of Evidence 404(b) and 403. Finally, the court found that the sentence was substantively reasonable and did not result in unwarranted sentencing disparity. View "USA V. BOUDREAU" on Justia Law

The defendant was apprehended after driving a vehicle containing nearly 50 pounds of methamphetamine and was convicted of possessing methamphetamine with intent to distribute. In seeking a reduced sentence, he argued that he played only a minor role as a courier in the drug operation, submitting a proffer that identified three other individuals allegedly involved in the scheme. The district court considered the sentencing guidelines, which allow for a downward adjustment if the defendant is a minor participant, but declined to apply the adjustment, finding insufficient evidence to support the claim.Prior to this appeal, the United States District Court for the Eastern District of Oklahoma reviewed the case. The defendant objected to the presentence report’s recommendation against the minor-role adjustment, but did not specifically object to the district court’s explanation for denying the adjustment at sentencing. The district court imposed a sentence of 235 months, at the bottom of the applicable guideline range, without the downward adjustment.On appeal, the United States Court of Appeals for the Tenth Circuit reviewed whether the district court plainly erred in denying the minor-role adjustment and whether the sentence was procedurally or substantively unreasonable. Applying the plain-error standard, the appellate court held that the district court did not err in its explanation or in its consideration of the defendant’s proffer, and that any ambiguity in the district court’s statements should be interpreted in a legally correct manner. The court further held that the sentence was both procedurally and substantively reasonable, as it fell within the guideline range and the district court was not required to explicitly address every statutory factor. The Tenth Circuit affirmed the sentence. View "United States v. Naranjo-Aguilar" on Justia Law

On August 29, 2020, a shooting occurred outside gas stations in DeKalb County, Georgia, resulting in the death of De’Andre Jones. Jedidja Mbungu was identified as the shooter. Witnesses testified that Mbungu and Jones encountered each other in the street, exchanged words, and then Mbungu shot Jones as Jones was running away. No gun was found on or near Jones, and the medical examiner determined that Jones died from a gunshot wound to the back of his head. Mbungu claimed self-defense, testifying that he believed Jones was armed and threatening him, based on prior violent encounters and Jones’s reputation.A DeKalb County grand jury indicted Mbungu for malice murder, felony murder, aggravated assault, and possession of a firearm during the commission of a felony. At trial in October 2023, the jury acquitted Mbungu of malice murder but convicted him of felony murder and the firearm charge. The aggravated assault count merged. The trial court sentenced Mbungu to life in prison plus a suspended five-year sentence for the firearm offense. Mbungu’s motion for a new trial was denied by the trial court in March 2025.The Supreme Court of Georgia reviewed the case. Mbungu argued that the trial court erred by excluding evidence of a prior difficulty with Jones and evidence of Jones’s alleged gang membership, and by refusing to instruct the jury on combat by agreement and mistake of fact. The Supreme Court of Georgia held that any error in excluding the evidence was harmless, as similar evidence was admitted and the self-defense claim was weak. The court also held that the trial court did not err in refusing the requested jury instructions, as the evidence did not support them. The convictions and sentences were affirmed. View "MBUNGU v. THE STATE" on Justia Law

A woman’s body was discovered inside a plastic container on the side of a Georgia interstate in January 2022. The victim was identified as Myra Smith Parlier. The investigation revealed that she died from asphyxia, with evidence indicating she was strangled with a dog leash and suffocated with a trash bag. Items found at her home matched those used in the concealment of her body. Jquantae Jester and his girlfriend, who had been staying at Parlier’s house, were linked to the crime through surveillance footage, use of Parlier’s financial cards, and possession of her belongings. Jester ultimately confessed to killing Parlier after confronting her about a sold shotgun, describing in detail how he strangled and suffocated her, then disposed of her body.A Fulton County grand jury indicted Jester for malice murder, felony murder, aggravated assault, and concealing the death of another. After a mistrial, a second trial resulted in Jester’s acquittal on malice murder but conviction on the remaining charges. The Superior Court of Fulton County sentenced him to life without parole for felony murder and a consecutive ten-year term for concealing the death. Jester’s motion for a new trial was denied, and he appealed to the Supreme Court of Georgia.The Supreme Court of Georgia reviewed several claims, including the admission of other-acts evidence, the lack of a jury instruction on confession corroboration, and alleged discovery violations. The court held that any error in admitting other-acts evidence was harmless due to overwhelming evidence of guilt and proper jury instructions. The omission of a confession corroboration instruction did not amount to plain error because the confession was amply corroborated. The court also found no plain error in admitting expert testimony despite alleged discovery violations. The convictions and sentences were affirmed. View "JESTER v. THE STATE" on Justia Law

On August 6, 2017, the appellant was involved in a fatal shooting after arranging to meet the victim, with whom he had a history of marijuana transactions. The meeting took place at an apartment complex where the appellant was staying. Witnesses observed the appellant acting nervously and possibly carrying a handgun. After the victim arrived, gunshots were heard, and the appellant was seen fleeing with what appeared to be a gun. He returned to the apartment, admitted to shooting someone, and then left the scene without contacting authorities. The victim was found dead with two gunshot wounds, and ballistic evidence linked the shots to a .45-caliber handgun. The appellant, a convicted felon, later testified that he shot the victim in self-defense during an attempted robbery.A Clayton County grand jury indicted the appellant for malice murder, felony murder, aggravated assault, and possession of a firearm by a convicted felon. At trial, the jury found him guilty on all counts. The trial court sentenced him to life without parole for malice murder, with additional consecutive sentences for aggravated assault and firearm possession. The felony murder counts were vacated by operation of law, and one aggravated assault count merged with the malice murder conviction. The appellant filed a motion for a new trial, which was initially granted but then vacated; the motion was ultimately denied. The case was transferred from the Court of Appeals to the Supreme Court of Georgia.The Supreme Court of Georgia held that the appellant’s trial counsel did not render ineffective assistance by failing to stipulate to his felon status or by eliciting testimony about his juvenile history, as these were either not deficient or were reasonable strategic decisions. However, the Court found a merger error regarding the aggravated assault conviction for the non-fatal shot and vacated that conviction and sentence. The remainder of the judgment was affirmed. View "FRASER v. THE STATE" on Justia Law