Justia Criminal Law Opinion Summaries

Three individuals, including the appellant, planned to rob a man they believed to be a drug dealer. The appellant drove the group to the meeting site and remained in the car while one co-defendant ultimately shot and killed the victim during the attempted robbery. All three were arrested and charged. One co-defendant cooperated with the government and received probation, while the appellant and the shooter proceeded to trial. The jury found the appellant guilty of first-degree (felony) murder while armed, attempted robbery while armed, and conspiracy. The Superior Court of the District of Columbia sentenced the appellant to an aggregate term of thirty years, with the sentences for conspiracy and attempted robbery running concurrently with the mandatory minimum for the murder conviction.The appellant appealed, arguing that being sentenced for both first-degree (felony) murder and the underlying felony violated the Double Jeopardy Clause. The District of Columbia Court of Appeals affirmed his convictions but remanded for resentencing to address the merger issue. On remand, the Superior Court considered whether it had discretion to vacate either the felony murder conviction or the underlying felony. The court indicated a preference for vacating the murder conviction due to the appellant’s lesser culpability but concluded, based on District of Columbia Court of Appeals precedent, that it was required to vacate the lesser underlying felony and retain the felony murder conviction.Upon renewed appeal, the District of Columbia Court of Appeals held that, when a defendant is convicted of both first-degree (felony) murder and the predicate felony, the trial court does not have discretion to choose which conviction to vacate. Instead, it must vacate the underlying felony and retain the felony murder conviction, unless legislative intent indicates otherwise. The court affirmed the Superior Court’s judgment. View "Hewitt v. United States" on Justia Law

The defendant was convicted of first-degree murder for the 1994 killing of Eileen Jones, whom he strangled in a park after borrowing his nephew’s car. Police discovered evidence at his home related to the crime, and he confessed to the killing, explaining that he feared Jones would accuse him of rape. The defendant had a prior voluntary manslaughter conviction from 1980. Following his conviction, he was sentenced to death. After initial post-conviction proceedings, the sentencing was vacated due to ineffective assistance of counsel, and the defendant was resentenced to death in 2012. At the resentencing, the Commonwealth introduced evidence that the defendant read books about murder and aspired to be a serial killer.After the resentencing, the defendant filed a Post Conviction Relief Act petition in the Court of Common Pleas of Delaware County, challenging the effectiveness of his resentencing counsel. The petition argued that counsel failed to adequately object to the Commonwealth’s use of evidence about his reading habits and alleged desire to be a serial killer. The court held evidentiary hearings and dismissed the petition, finding that counsel’s actions were reasonable and that the defendant did not demonstrate prejudice.On direct appeal, the Supreme Court of Pennsylvania reviewed whether resentencing counsel was ineffective for not adequately objecting to the Commonwealth’s evidence and arguments characterizing the defendant as a serial killer. The Court concluded that the evidence about reading murder books and aspiring to be a serial killer was inadmissible during the penalty phase, as it was irrelevant and unfairly prejudicial. The Court found that counsel’s failure to object constituted ineffective assistance and that there was a reasonable probability at least one juror may have struck a different balance but for the error. The Court reversed the lower court’s order and remanded for a new penalty-phase hearing. View "Commonwealth v. Smith" on Justia Law

The case involves an individual who was indicted for first-degree premeditated murder following the shooting death of his wife inside their shared home. The defendant did not dispute firing the fatal shot but claimed he did so during a struggle with an alleged intruder. Evidence at trial included a 911 call from the victim moments before her death, testimony regarding the absence of forced entry at the scene, the defendant’s financial difficulties leading to imminent home foreclosure and eviction, and his statements to police about the events and his actions that morning. There was also testimony about the trajectory of the gunshot, the state of the home, and the behavior of the defendant following the incident.A Ramsey County grand jury indicted the defendant, and he pleaded not guilty, electing a jury trial. At trial in Ramsey County District Court, the defendant twice moved for a judgment of acquittal before the verdict, arguing insufficient evidence; both motions were denied using the direct-evidence standard. The jury found the defendant guilty of first-degree premeditated murder, and the district court entered a conviction and imposed a life sentence without the possibility of release.On direct appeal, the Minnesota Supreme Court considered whether the circumstantial evidence was sufficient to support the conviction and whether the district court applied the correct standard in ruling on pre-verdict motions for acquittal. The Supreme Court held that the circumstantial evidence, when viewed as a whole, supported only the inference that the defendant caused his wife’s death with premeditation and intent. The Court also held that, when ruling on motions for acquittal made and decided before a verdict is returned, a district court should apply the direct-evidence standard, even if the case relies entirely on circumstantial evidence. The conviction was affirmed. View "State of Minnesota vs. Firkus" on Justia Law

In this case, the defendant was convicted of first-degree murder and robbery with a firearm for the 1991 killing of a police officer during a traffic stop. After initial convictions and a direct appeal, a new penalty phase was ordered, and the defendant was again sentenced to death in 1996. The trial court found two aggravating factors, including that the murder was committed during a robbery and to hinder law enforcement, outweighing the mitigating circumstances related to the defendant’s age, confession, courtroom behavior, and difficult childhood. The Florida Supreme Court affirmed the convictions and death sentence, which became final in 2001. Over the following decades, the defendant pursued numerous unsuccessful challenges to the conviction and sentence in state and federal courts.Following the signing of a death warrant in January 2026, the defendant filed a sixth successive motion for postconviction relief in the Circuit Court for St. Lucie County. He raised three claims: newly discovered evidence of jury influence by uniformed officers, a claim of intellectual disability based on a recent IQ test, and a challenge to the constitutionality of Florida’s death warrant process. The circuit court summarily denied all claims, as well as related motions for a juror interview, to declare the intellectual disability standard unconstitutional, and for late-filed public records requests.On review, the Supreme Court of Florida affirmed the circuit court’s denial of postconviction relief, denied the habeas corpus petition, and denied the motions for a stay of execution. The Court held that the claims of improper jury influence and intellectual disability were untimely and procedurally barred, the request for a juror interview and public records were properly denied as untimely and speculative, and that the intellectual disability claim was also legally insufficient. The Court further declined to extend Eighth Amendment protections beyond current U.S. Supreme Court precedent. View "Kearse v. State" on Justia Law

A woman was reported to military authorities at Joint Base San Antonio Lackland by a concerned parent in April 2022. The parent alleged that the woman sent explicit text messages to her thirteen-year-old son, provided him a cell phone, and facilitated meetings between him and her own twelve-year-old daughter. An investigation revealed that the woman encouraged and orchestrated sexual activity and explicit exchanges between the children. She was charged with several federal sex offenses but, pursuant to a plea agreement, pleaded guilty to a single offense—Sexual Performance by a Child—under the Assimilative Crimes Act (ACA), which incorporates Texas Penal Code § 43.25 into federal law.The United States District Court for the Western District of Texas classified her conviction as a Class A felony by reference to the Texas statute’s penalties. The Presentence Report (PSR) and the district court applied 18 U.S.C. § 3583(k), which governs supervised release for enumerated federal sex offenses, sentencing her to 325 months in prison and thirty years of supervised release. She appealed her sentence, arguing that the proper statutory maximum for supervised release should be five years under 18 U.S.C. § 3583(b), not the five years to life provided by § 3583(k). The government responded that the sentence was permissible, as it did not exceed the Texas statutory maximum and that the most analogous federal offense fell within § 3583(k).The United States Court of Appeals for the Fifth Circuit held that § 3583(k) applies only to the specific federal offenses enumerated within it and not to offenses assimilated under the ACA. The court found the statutory text unambiguous and determined that the supervised release term for the assimilated state offense was subject to the general five-year maximum set by § 3583(b). The court vacated the thirty-year supervised release term and remanded for resentencing within the proper statutory maximum. View "USA v. Swarner" on Justia Law

In this case, the defendant was charged with first-degree premeditated murder and felony-firearm after a circuit judge, acting as a one-person grand jury under Michigan’s statutory scheme, filed a two-count indictment against him. The defendant moved for a preliminary examination or to quash the information, but the trial court denied the motion. A jury later convicted him on both counts. The defendant’s direct appeal and first motion for relief from judgment were unsuccessful. Following the Michigan Supreme Court’s decision in People v Peeler, which held that a defendant charged under the one-person grand jury law is entitled to a preliminary examination and that a judge may not issue a criminal indictment under that law, the defendant filed a second motion for relief from judgment, arguing that Peeler applied retroactively and rendered his indictment—and thus his convictions—void for lack of subject-matter jurisdiction.The Jackson Circuit Court denied the defendant’s second motion, finding Peeler did not apply retroactively and, even if it did, the defendant could not show prejudice because the jury convicted him after a fair trial. The Michigan Court of Appeals affirmed, holding that Peeler did not affect subject-matter jurisdiction, did not announce a new rule of law, and did not apply retroactively on collateral review.Upon review, the Michigan Supreme Court affirmed in part and vacated in part. It held that, although Peeler established a new rule of law by barring one-person grand jury indictments and requiring preliminary examinations, violations of Peeler do not implicate a circuit court’s subject-matter jurisdiction and do not apply retroactively on collateral review. The Court affirmed the denial of relief on alternative grounds but vacated the Court of Appeals’ conclusion that Peeler did not announce a new rule of law. View "People Of Michigan v. Robinson" on Justia Law

During his murder trial, the defendant chose to testify in his own defense, claiming self-defense in the fatal stabbing. Partway through his testimony, the trial was interrupted by a 24-hour overnight recess. Before the break, the trial judge instructed the defendant’s attorneys not to “manage” or shape his ongoing testimony during the recess but clarified that the defendant was not barred from speaking with his lawyers about other matters, such as sentencing or trial strategy. After the recess, the defendant resumed testifying and was later convicted of murder.Upon appeal, the Texas Court of Criminal Appeals reviewed the trial judge’s conferral order. The appellate court found that the order was constitutionally permissible because it only restricted discussions specifically about managing the defendant’s ongoing testimony, not all attorney-client consultations. The appellate court emphasized that the order did not prevent the defendant from consulting his attorneys on other protected matters, such as plea negotiations or trial strategy, and was therefore a proper exercise of the trial court’s discretion.The Supreme Court of the United States addressed whether a qualified order limiting discussion of a defendant’s ongoing testimony during a midtestimony overnight recess violates the Sixth Amendment right to counsel. The Supreme Court held that such a qualified order is constitutional, so long as it prohibits only discussion of testimony for its own sake and does not prevent consultation on other protected topics, including trial strategy, plea discussions, or evidentiary issues. The Court distinguished this qualified order from a total ban on attorney-client discussions and affirmed that the order properly balanced the defendant’s right to counsel against the integrity of unaltered trial testimony. The judgment of the Texas Court of Criminal Appeals was affirmed. View "Villarreal v. Texas" on Justia Law

Law enforcement initiated a multi-agency investigation in Millville, New Jersey, following a series of shootings, aiming to address local gun violence and weapons trafficking. The defendant was not initially linked to the violence but became a subject after a wiretap intercepted calls about a potential firearm purchase. Surveillance led police to search an apartment they saw the defendant enter; they recovered heroin, cocaine, drug paraphernalia, and two revolvers. Though one witness initially connected a weapon to the defendant, he later recanted. The defendant was arrested and charged with controlled dangerous substances (CDS) and weapons offenses.The Superior Court, Law Division, handled pretrial motions to limit references to search warrants and the Organized Crime Bureau, with the State agreeing to certain restrictions. During trial, the prosecutor referenced the television show The Wire in opening statements, drawing parallels to organized crime. State witnesses made repeated references to gun violence, weapons trafficking, and the Organized Crime Bureau. Despite objections, the State and its witnesses repeatedly mentioned the search warrant. The jury acquitted the defendant of weapons charges but convicted him of CDS offenses. The Superior Court, Appellate Division, affirmed the convictions, finding no reversible errors either individually or cumulatively.The Supreme Court of New Jersey reviewed whether the prosecutor’s references to The Wire, gun violence, and the search warrant, as well as to the Organized Crime Bureau, deprived the defendant of a fair trial. The Court held that, while no single error warranted reversal on its own, the cumulative effect of these improper references undermined the fairness of the proceedings and deprived the defendant of his constitutional right to a fair trial. Accordingly, the judgment was reversed and the matter remanded for a new trial. View "State v. Butler" on Justia Law

In January 2020, William Jimenez sold fentanyl-laced heroin to an undercover New York City police detective, arranging the transactions by phone. During the same period, Jimenez shot another individual and was arrested soon after. A search revealed drugs and ammunition in his possession and vehicle. He was indicted on several counts, including possessing ammunition after a felony conviction, firearm discharge related to drug trafficking, and multiple counts of distributing controlled substances. Jimenez ultimately pled guilty to possessing ammunition after a felony conviction under 18 U.S.C. § 922(g)(1), pursuant to a plea agreement that included an appeal waiver for sentences within a stipulated Guidelines range.The United States District Court for the Southern District of New York sentenced Jimenez to 105 months’ imprisonment and three years of supervised release, imposing seven special conditions, three of which he later challenged. On a prior appeal, the United States Court of Appeals for the Second Circuit vacated and remanded the case, requiring the District Court to provide individualized justifications for the challenged special conditions. On remand, the District Court reimposed the conditions with further explanation. Jimenez appealed again, contesting the special conditions and seeking resentencing based on a change in the law affecting his Guidelines calculation.The United States Court of Appeals for the Second Circuit affirmed the District Court’s judgment. It held that the special conditions—electronic device searches, community service requirements during unemployment, and outpatient mental health counseling—were procedurally and substantively reasonable, supported by the record, and tailored to Jimenez’s history and circumstances. The Court also held that Jimenez’s appeal waiver barred his challenge to the term of imprisonment, even in light of an intervening change in the law. The judgment of the District Court was therefore affirmed. View "United States v. Jimenez" on Justia Law

A young man, referred to as Jared, was charged with battery to a law enforcement officer after an incident in which he threatened his family and police, and struck an officer. Following his arrest, concerns about Jared’s mental health led to a competency evaluation. He was diagnosed with schizophrenia and found incompetent to stand trial. While initially taking prescribed medication inconsistently in jail, Jared later refused medication in a mental health institution, resulting in disruptive and aggressive behavior. The State, through a Department of Health Services doctor, sought and obtained a Milwaukee County Circuit Court order for involuntary medication to restore Jared’s competency for trial.On appeal, Jared challenged the involuntary medication order, arguing that neither the statutory requirements under Wisconsin law nor the constitutional standards articulated in Sell v. United States were met. The Wisconsin Court of Appeals reversed, finding the circuit court’s findings on both the statutory and Sell factors clearly erroneous and concluding that the State had not sufficiently established any of the four Sell factors necessary for involuntary medication.The Supreme Court of Wisconsin reviewed the case to clarify the standard of appellate review for each of the Sell factors and to determine whether the circuit court’s application of those factors and the statutory requirements was correct. The Supreme Court held that the question of whether an important governmental interest exists (Sell factor one) is reviewed de novo, while the remaining three Sell factors (significant furtherance of the interest, necessity, and medical appropriateness) are findings of fact reviewed for clear error. The Supreme Court found that the State’s interest in prosecuting Jared was important and not sufficiently diminished by special circumstances. It further held that the lower court’s findings on the remaining Sell factors and the statutory requirements were not clearly erroneous. The Supreme Court reversed the Court of Appeals, reinstating the circuit court’s order for involuntary medication. View "State v. J. D. B." on Justia Law