Justia Criminal Law Opinion Summaries

After pleading guilty to federal drug-distribution conspiracy charges in 2012, the defendant was sentenced to ten years in prison followed by eight years of supervised release. He began his supervised release in 2019. In 2022, while still under supervision, he shot and killed a man outside a convenience store, an act captured on security video. He subsequently pled guilty to murder in state court. This new criminal conduct constituted a violation of the conditions of his federal supervised release.Following the murder conviction, the United States District Court for the Eastern District of Michigan revoked the defendant’s supervised release. At the revocation hearing, the court considered the advisory Sentencing Guidelines, which recommended a range of 51 to 63 months, but imposed the statutory maximum of 60 months’ imprisonment. The court ordered this sentence to run consecutively to the defendant’s state sentence. The defendant objected to both the length of the federal sentence and the decision to run it consecutively, but did not object to the court’s consideration of the seriousness of the supervised-release violation.On appeal, the United States Court of Appeals for the Sixth Circuit reviewed the procedural and substantive reasonableness of the sentence. Applying plain-error review to the procedural challenge, the court held that the district court did not treat the seriousness of the supervised-release violation as a mandatory factor, but permissibly considered it as a breach of trust. The court also found no abuse of discretion in the substantive reasonableness of the sentence, noting that the district court considered multiple relevant factors and imposed a within-Guidelines sentence. The Sixth Circuit affirmed the district court’s judgment. View "United States v. Patterson" on Justia Law

Gregory Bonnie was serving a 144-month federal prison sentence in South Carolina, consisting of 120 months for drug trafficking convictions and a consecutive 24 months for violating supervised release, which included a conviction under 18 U.S.C. § 924(c) for possession of a firearm during a drug trafficking crime. While incarcerated, Bonnie sought to earn time credits under the First Step Act (FSA) for the 120-month portion of his sentence related to drug offenses, acknowledging that the 24-month portion for the § 924(c) conviction was disqualifying under the FSA.The Bureau of Prisons (BOP) denied Bonnie’s request, treating his consecutive sentences as a single, aggregate term of imprisonment pursuant to 18 U.S.C. § 3584(c), and finding him ineligible for FSA time credits because his aggregate sentence included a disqualifying § 924(c) conviction. After exhausting administrative remedies, Bonnie filed a habeas petition under 28 U.S.C. § 2241 in the United States District Court for the District of South Carolina. The district court granted summary judgment for the warden, holding that the plain text and statutory context of the FSA and § 3584(c) required aggregation of sentences, making Bonnie ineligible for FSA time credits for the entire 144-month sentence.On appeal, the United States Court of Appeals for the Fourth Circuit reviewed the statutory interpretation de novo. The court held that, under the FSA and § 3584(c), the BOP must treat multiple consecutive or concurrent sentences as a single, aggregate sentence for administrative purposes, including the computation of FSA time credits. Because Bonnie’s aggregate sentence included a conviction under § 924(c), he was ineligible for FSA time credits for any portion of the sentence. The Fourth Circuit affirmed the district court’s judgment denying Bonnie’s habeas petition. View "Bonnie v. Dunbar" on Justia Law

The appellant was convicted of first-degree murder for killing his estranged wife’s 14-month-old son, as well as attempted murder and aggravated assault of his estranged wife’s roommate. The prosecution’s case relied heavily on the testimony of a police officer who witnessed the events. At trial, the appellant represented himself and claimed innocence, alleging a police cover-up. During jury selection, one juror initially indicated on a questionnaire that a family member had been charged with a crime, but then changed the answer to “no.” Decades later, the appellant’s counsel discovered that this juror’s nephew had, in fact, been charged with attempted murder of an infant before the trial, a fact not disclosed during voir dire.The Court of Common Pleas of Dauphin County dismissed the appellant’s third Post Conviction Relief Act (PCRA) petition as untimely, reasoning that the information about the juror’s nephew was available in a 2002 news article and thus not a “new fact.” The court concluded that the appellant failed to show why he could not have discovered this information earlier, and therefore did not meet the requirements for the previously unknown fact exception to the PCRA’s time bar.The Supreme Court of Pennsylvania reviewed the dismissal de novo. It held that the lower court erred by applying a presumption that the appellant knew of the juror’s family connection simply because the information was publicly available. The Supreme Court clarified that the relevant inquiry is whether the appellant actually knew or could have discovered the fact through reasonable diligence, not whether the information was in the public record. The Court vacated the order dismissing the petition and remanded for further proceedings, holding that the appellant was entitled to a hearing to establish whether he met the requirements for the newly discovered fact exception. View "Commonwealth v. Blakeney" on Justia Law

The case involved a defendant who was convicted by a jury of two counts of gross sexual imposition, one a class AA felony and one a class A felony. During jury deliberations, the jury requested to review a recorded interview that was part of the evidence. Because there was no device available for the jury to listen to the recording in the jury room, the district court decided to play the recording in the courtroom. The court then closed the courtroom to the public during this process, reasoning that the jury’s review of evidence constituted deliberations, which required exclusion of the public.The District Court of Dunn County, Southwest Judicial District, presided over the trial and made the decision to close the courtroom. The defendant did not object to the closure at trial but did ask the court to consider whether reviewing evidence was truly deliberation. The court performed a Waller v. Georgia analysis and found that an overriding interest justified closure, and both parties agreed the findings were adequate for the record. The defendant was convicted and sentenced to a 20-year term, with 10 years suspended, and the sentences to run concurrently.On appeal, the Supreme Court of North Dakota reviewed whether the closure of the courtroom during the jury’s review of evidence violated the defendant’s right to a public trial. The court held that the district court erred by treating the jury’s review of evidence as deliberations requiring closure. The Supreme Court found this was a plain and obvious error that affected the defendant’s substantial rights, constituting a structural error. The Supreme Court of North Dakota reversed the judgment and remanded the case for a new trial, holding that the closure of the courtroom under these circumstances violated the defendant’s constitutional right to a public trial. View "State v. Barrett" on Justia Law

A defendant was arrested following a report of sexual misconduct and charged with four counts of gross sexual imposition involving a minor. The victim testified that the defendant’s sexual contact began when she was six years old and continued regularly from 2013 to 2016. The victim’s mother testified that the defendant admitted to an instance of sexual contact in 2013, and the victim’s brother corroborated that the victim disclosed the abuse to him, which he later reported to a school counselor. The case proceeded to a jury trial, where the victim and her family members testified about the frequency and nature of the abuse.The District Court of Burke County, North Central Judicial District, presided over the trial. During jury deliberations, the jury requested to review an audio recording, which was replayed in open court due to the lack of a clean computer for use in the jury room. After the recording was played, the defendant’s attorney moved for a mistrial, alleging that the victim’s mother made audible noises in the courtroom that could have influenced the jury. The court denied the motion, noting that neither the judge, the State, nor defense counsel (apart from the defendant’s own observation) noticed any such noises. The jury found the defendant guilty on all four counts, and each juror affirmed that the presence of others in the courtroom did not affect their verdicts.On appeal, the Supreme Court of North Dakota reviewed whether there was sufficient evidence to support the convictions and whether the district court abused its discretion in denying the motion for mistrial. The court held that the victim’s testimony, even without specific instances for each year, was sufficient to support the convictions. The court also found no actual prejudice from the alleged courtroom noises and concluded the district court did not abuse its discretion. The judgment was affirmed. View "State v. Watterud" on Justia Law

Carrie Cotton was charged in four separate cases with multiple class A misdemeanor offenses, including stalking, harassment, and violating a disorderly conduct restraining order. The charges stemmed from her alleged harassment of her ex-boyfriend, T.B., and his acquaintances, H.C., B.C., and T.C., including sending numerous messages from various phone numbers and fake social media accounts. Despite a restraining order, Cotton continued to contact the victims with explicit and vulgar messages. She entered Alford pleas of guilty to all charges.The District Court of Foster County, Southeast Judicial District, presided by Judge James D. Hovey, sentenced Cotton to consecutive prison terms of 360 days on four separate counts, each relating to different victims and incidents. The court also imposed suspended terms of imprisonment on the remaining counts and ordered two years of probation. Cotton appealed, arguing that the consecutive sentences for misdemeanor offenses violated North Dakota’s statutory prohibition against such sentencing, claiming her actions constituted a single course of conduct.The Supreme Court of the State of North Dakota reviewed the case. The court held that an exception to the general rule against consecutive sentences for misdemeanors applied because each offense was committed as part of a different course of conduct, involving distinct acts against different victims on different dates. The court found that similarity in method and motive did not render the offenses part of the same course of conduct. The court also rejected Cotton’s argument that the district court failed to make necessary factual findings, concluding that the facts were undisputed and the legal standard was met. The Supreme Court affirmed the amended criminal judgments, holding that the consecutive sentences were lawful under the statutory exception. View "State v. Cotton" on Justia Law

Joseph Miller was charged in two separate criminal cases with aggravated assault and violations of a domestic violence protection order (DVPO). In one case, the charge for violating a DVPO was amended from a felony to a misdemeanor after a prior violation was dismissed. Miller entered an Alford plea to aggravated assault and pled guilty to the amended misdemeanor DVPO violation and a felony DVPO violation in the second case. He was sentenced to concurrent terms of incarceration and probation, with some time suspended and conditions including electronic monitoring and participation in sobriety and anger management programs.The District Court of Nelson County, Northeast Central Judicial District, presided over Miller’s cases. After Miller failed to comply with probation conditions—including repeated alcohol violations and failure to complete required programs—the State petitioned to revoke his probation. At the revocation hearing, Miller admitted to the remaining alleged violations. The district court found Miller violated probation, revoked it, and resentenced him. However, the court did not orally pronounce a new sentence for the misdemeanor DVPO violation in one case, and the amended judgment classified it as a felony, contrary to the earlier amendment.The Supreme Court of North Dakota reviewed Miller’s appeal, applying a two-step analysis for probation revocation: reviewing factual findings for clear error and the revocation decision for abuse of discretion. The court held that the district court’s findings of probation violations were supported by the record and not clearly erroneous, and that revocation and incarceration were not an abuse of discretion. The Supreme Court affirmed the revocation and sentence in the felony DVPO case, affirmed the findings and sentence for aggravated assault, but reversed and remanded for proper sentencing on the misdemeanor DVPO violation, as the sentence in the amended judgment was inconsistent with the oral pronouncement. View "State v. Miller" on Justia Law

A defendant was convicted by a jury in 2018 on two felony counts of gross sexual imposition involving the seven-year-old daughter of his girlfriend. The prosecution’s case included the child’s testimony, a video of her forensic interview, statements from her mother and babysitter, and evidence of the defendant’s conduct and statements before and after the alleged incident. The State also introduced evidence of the defendant’s internet searches for incest-related pornography, which was not referenced in closing arguments and comprised a small portion of the trial record.On direct appeal, the North Dakota Supreme Court affirmed the conviction, noting that the defendant’s counsel had failed to object to the admission of the internet search evidence under North Dakota Rule of Evidence 404(b), and thus forfeited the issue. The defendant then sought postconviction relief in the District Court of Burleigh County, arguing ineffective assistance of counsel for failing to object to the Rule 404(b) evidence and for not arguing obvious error on appeal. The district court granted relief, finding counsel’s performance deficient under the first prong of Strickland v. Washington and concluding, with minimal explanation, that the defendant was prejudiced under the second prong.The Supreme Court of North Dakota reviewed the case. It held that the district court did not err in finding counsel’s performance fell below an objective standard of reasonableness. However, the Supreme Court found the district court’s analysis of prejudice insufficient, as it did not assess the impact of counsel’s errors in the context of the remaining evidence and the overall trial. The Supreme Court affirmed the finding of deficient performance, reversed the finding of prejudice, and remanded for further proceedings, instructing the district court to supplement the record if possible and conduct the required prejudice analysis under Strickland. View "Smith v. State" on Justia Law

The case concerns a defendant who was charged with four federal sex-trafficking offenses involving two victims, one an adult and the other a minor. The defendant, who identified himself as a pimp, transported both victims from Atlanta to Miami in advance of the 2020 Super Bowl, intending for them to perform sex work. The adult victim testified that she was threatened and coerced into working for the defendant, while the minor victim, who was seventeen, did not testify at trial. Evidence included social media posts, communications between the defendant and the victims, and testimony about the defendant’s control over the victims. The minor victim was apprehended during a police sting operation in Miami, and her statements to police were admitted at trial despite her absence as a witness.The United States District Court for the Southern District of Florida presided over the trial. The jury convicted the defendant on all four counts: sex trafficking of the adult victim by force and coercion, transporting the adult victim to engage in sexual activity, sex trafficking of the minor victim, and transporting the minor victim to engage in sexual activity. The defendant was sentenced to 300 months in prison and ten years of supervised release. He appealed, arguing that the admission of the minor victim’s statements violated the Confrontation Clause and hearsay rules, that the jury instructions for two counts constructively amended the indictment, and that the evidence was insufficient for two counts.The United States Court of Appeals for the Eleventh Circuit reviewed the case. It held that the minor victim’s statements were nontestimonial and thus did not violate the Confrontation Clause, and that any hearsay error was harmless. The court found that while the jury instructions for two counts constructively amended the indictment, these errors did not amount to plain error. The court also concluded that sufficient evidence supported all convictions. The Eleventh Circuit affirmed the convictions. View "USA v. Carter" on Justia Law

A man was charged with multiple sexual offenses, including forcible rape, forcible oral copulation, unlawful intercourse, and incest, all involving his 17-year-old immediate relative. The alleged incident occurred when the defendant stayed overnight at the victim’s home, entered her bedroom, and engaged in sexual acts without her consent. The victim testified about the charged incident and two prior uncharged incidents involving the defendant, one when she was eight years old and another a few weeks before the charged offenses. The defendant denied all wrongdoing and provided alternative explanations for his actions. The prosecution presented expert testimony on the psychology of child sexual assault victims and admitted evidence of the defendant’s statements during pretext phone calls.The Monterey County Superior Court jury found the defendant guilty on all counts. He was sentenced to 17 years in prison, with sentences for unlawful intercourse and incest stayed. The defendant appealed, arguing insufficient evidence for some counts, improper jury instructions regarding the definition of force, erroneous admission of uncharged acts, and ineffective assistance of counsel for failing to object to certain evidence and testimony.The California Court of Appeal, Sixth Appellate District, found that the trial court erred by granting the prosecution’s request to modify the pattern jury instructions on the definition of force, which misled the jury regarding an essential element of the forcible rape and forcible oral copulation charges. This error was deemed prejudicial, requiring reversal and remand for possible retrial on those counts. The court found sufficient evidence supported the convictions for unlawful intercourse and incest, and that other asserted errors were either harmless or did not constitute ineffective assistance. The convictions for unlawful intercourse and incest were affirmed, while the convictions for forcible rape and forcible oral copulation were reversed and remanded. View "P. v. Melgoza" on Justia Law