Justia Criminal Law Opinion Summaries

After an evening involving alcohol, three men—Keith, his brother Dannie, and Bryant—traveled together in Dannie’s truck. The next morning, Bryant was found in the road with a fatal head injury. During the investigation, Dannie provided law enforcement with inconsistent stories but eventually stated that Keith struck Bryant on the head with a club-like object during an argument, after which Bryant did not recover. A search of Dannie’s truck revealed an object matching Dannie’s description. Other witnesses corroborated that the three men left together and that Bryant did not return. The medical examiner concluded that Bryant’s death was a homicide caused by blunt-force trauma.The Copiah County Circuit Court conducted a jury trial. The prosecution introduced autopsy photographs over defense objections, and Dannie testified, admitting his own inconsistent statements. The jury found Keith guilty of second-degree murder but deadlocked on sentencing, resulting in a statutorily mandated thirty-year sentence.On appeal to the Supreme Court of Mississippi, Keith challenged the admission of certain autopsy photographs, the sufficiency of the evidence (arguing that Dannie’s testimony was unreliable), and the propriety of the jury instructions on depraved-heart murder and culpable-negligence manslaughter. The Supreme Court of Mississippi held that the trial court did not abuse its discretion in admitting the photographs, as they supplemented the pathologist’s testimony and were probative given the disputed manner of death. The Court found that the jury was entitled to judge Dannie’s credibility and that the verdict was not against the overwhelming weight of the evidence. The Court also determined that the jury instructions, considered as a whole, properly explained the hierarchy and definitions of the offenses. Any possible error in the manslaughter instructions was deemed harmless, as the jury convicted Keith of murder. The Supreme Court of Mississippi affirmed Keith’s conviction and sentence. View "Goods v. State of Mississippi" on Justia Law

The defendant pleaded guilty to criminal confinement and interfering with reporting a crime, resulting in a five-year sentence: two years served through time already served and work release, followed by three years of probation. The plea agreement specified that violating any court-sponsored program, such as work release, would result in revocation and execution of the sentence. In 2023, the defendant failed to return to the work release facility, prompting his community corrections case manager to file a petition seeking revocation of his work release placement. The petition, however, did not mention probation or request revocation of the suspended portion of his sentence.After the defendant was later arrested and pleaded guilty to failure to return to lawful detention, the trial court addressed both the work release violation and, upon the State’s oral request, the defendant’s probation. Despite the defendant’s counsel objecting that revoking probation without a specific petition violated due process, the trial court revoked both his work release privileges and his probation, ordering the remainder of his sentence executed in the Department of Correction.On appeal, the Indiana Court of Appeals affirmed the trial court, holding that the court had statutory authority to revoke probation and that due process was satisfied through the plea agreement and the notice provided by the work release revocation petition. The defendant sought further review.The Indiana Supreme Court granted transfer, vacated the Court of Appeals opinion, and reversed the probation revocation. The Court held that due process requires that the State may only seek sanctions identified in the revocation petition or for which the defendant has actual notice. Because there was no petition or adequate notice seeking probation revocation, the trial court’s order revoking probation was improper. View "Ewing v. State" on Justia Law

A Texas-based company distributed files online that enabled the 3D printing of functional, untraceable firearms. After New Jersey’s Attorney General issued a cease-and-desist letter and the state legislature enacted a statute prohibiting the distribution of such files to unlicensed individuals, the company and an affiliated nonprofit restricted New Jersey residents from accessing these files. The plaintiffs challenged the actions, alleging violations of the First, Second, and Fourteenth Amendments.Initially, the plaintiffs filed suit in the Western District of Texas, which dismissed the case for lack of personal jurisdiction. Plaintiffs then filed a similar suit in the District of New Jersey, alleging the statute constituted criminal censorship. After complex procedural maneuvers—including appeals and transfers between Texas and New Jersey, and requests for retransfer—the litigation proceeded in the District of New Jersey, which consolidated the relevant cases.The United States Court of Appeals for the Third Circuit reviewed the District of New Jersey’s decision to dismiss the complaint with prejudice. The Third Circuit affirmed the lower court’s rulings. It held that the district court did not abuse its discretion in denying retransfer to Texas. The court further held that the plaintiffs lacked standing to bring a Second Amendment claim, as there were no allegations that any plaintiff or member was prevented from 3D-printing a firearm. The court also found the statute was not void for vagueness under the Due Process Clause, as it provided fair notice of prohibited conduct. Finally, the court held that plaintiffs failed to plead sufficient facts showing that the computer code at issue was expressive and entitled to First Amendment coverage, as the complaint did not detail the nature or expressive use of the files. The dismissal with prejudice was affirmed. View "Defense Distributed v. Attorney General New Jersey" on Justia Law

The case concerns an individual who, in June 2025, was sentenced to two consecutive 30-month terms of incarceration, with the judgment stating he would receive credit for time served under Oregon law. Following the Oregon Supreme Court’s decision in State ex rel Torres-Lopez v. Fahrion, the Oregon Department of Corrections (DOC) recalculated his sentence and determined his release date had already passed, resulting in his release in August 2025. Subsequently, the Jackson County District Attorney sought to amend the judgment, aiming to alter the language regarding sentence credits. DOC then revised its interpretation of the law, concluded the individual still had time to serve, and issued an order for his re-arrest under ORS 144.350, which led to his return to custody in November 2025. The District Attorney then withdrew the motion to correct the judgment, and the trial court granted that withdrawal. After the Oregon Supreme Court decided Arellano-Sanchez v. Thrasher and related cases, which held that DOC lacked authority under ORS 144.350 to re-arrest similarly situated individuals, the District Attorney again moved to amend the judgment to remove the credit language, but the trial court denied the motion. The plaintiff then petitioned the Oregon Supreme Court for a writ of habeas corpus, asserting his circumstances were indistinguishable from those in recent Supreme Court decisions granting relief. The Supreme Court of the State of Oregon held that, as in Arellano-Sanchez and several companion cases, DOC did not have authority under ORS 144.350 or any other source to order the plaintiff’s arrest and continued imprisonment. The court ordered the plaintiff’s immediate release, waived procedural rules regarding reconsideration and judgment issuance, and clarified that circuit courts are equipped to handle future similar habeas petitions. View "Robinson v. Hendricks" on Justia Law

The defendant was charged with multiple counts of terrorizing with a dangerous weapon or firearm and one count of preventing arrest after allegedly threatening to shoot or kill people at a restaurant in Minot, North Dakota. The prosecution claimed that the defendant made verbal threats, stated he had a gun in his backpack, gestured toward the backpack, and was later found to possess a firearm in the backpack after his arrest. The restaurant manager and a patron testified that, while they did not see the firearm, the defendant claimed to have it and threatened to use it.The District Court of Ward County dismissed seven of the eight terrorizing counts before trial. The defendant proceeded to a bench trial on one count of terrorizing and one count of preventing arrest. He stipulated to the essential elements of the terrorizing offense, disputing only whether the mandatory minimum sentence for use of a firearm applied. The trial judge found the defendant guilty on both counts and made a special finding that he possessed a firearm during the offense. The court concluded that the armed offender statute applied, ruling that possession and threat to injure using a firearm sufficed, without requiring the gun to be brandished or displayed.On appeal, the Supreme Court of North Dakota reviewed whether the district court properly interpreted and applied N.D.C.C. § 12.1-32-02.1, which mandates a minimum sentence for certain offenses involving firearms. The Supreme Court held that the statute does not require a firearm to be brandished or displayed; it is sufficient if the offender threatens to injure another through the use or means of a firearm while possessing it. The court found the district court’s interpretation reasonable and supported by the evidence and affirmed the judgment, including the mandatory minimum sentence. View "State v. Reese" on Justia Law

The defendant was charged with terrorizing—domestic violence, a class C felony, after an incident involving his ex-wife, who is also the mother of his minor child. The district court imposed a pre-dispositional order prohibiting contact with the victim, initially for thirty days. After the defendant pled guilty, the court sentenced him to two years, including three days to serve (with credit for time served) and two years of supervised probation. As a condition of probation, the court extended the no-contact order for two years, prohibiting all direct or indirect contact with the victim, including communication relevant to their minor child.After sentencing, the defendant requested an exception to allow necessary communications with the victim regarding court-ordered parenting time with their child. The district court declined, stating the defendant was not prohibited from having contact with his child but failed to provide any method for arranging parenting time, given the victim’s residential responsibility and the communication restrictions. The defendant appealed the judgment and the order extending the no-contact provision.The Supreme Court of the State of North Dakota reviewed the case. It held that, although the district court acted within statutory limits and did not rely on any impermissible factor (so the sentence was not illegal), it abused its discretion by failing to provide a means for the defendant to arrange contact with his child or to explain why no such method was allowed. The court determined that, under these circumstances, the blanket prohibition on contact with the victim—including for purposes of exercising parental rights—was arbitrary and not the result of a reasoned decision. The Supreme Court of North Dakota reversed the criminal judgment and the order extending the order prohibiting contact and remanded for resentencing, instructing the district court to consider alternatives that would permit the defendant to exercise his parental rights. View "State v. Maher" on Justia Law

In this case, the appellant was convicted by a Drew County jury in 1996 for capital murder during a robbery, based largely on eyewitness identifications, physical evidence linking him to the crime, and his own conflicting statements about his involvement. At trial, two witnesses identified him as fleeing the scene with a weapon, and forensic testimony indicated that the victim’s blood type matched stains found on the appellant’s shirt. The appellant testified that he was outside during the shooting, but earlier statements placed him inside as a lookout. His conviction and life sentence were affirmed on direct appeal. The appellant subsequently filed multiple petitions for postconviction relief. In 2012, he sought DNA testing under Act 1780 of 2001, claiming actual innocence and arguing that DNA analysis of blood evidence would exonerate him. The Drew County Circuit Court denied relief, and the Supreme Court of Arkansas affirmed, finding he failed to rebut timeliness presumptions. In 2020, he filed another petition, seeking new DNA testing using methods not previously available, such as M-VAC technology, on various items from the crime scene. The circuit court again denied the petition, ruling it was an impermissible successive filing and that the issues had already been decided. The Supreme Court of Arkansas reviewed this appeal and affirmed the lower court’s decision. It held the petition was both successive and untimely under Arkansas law. The Court found that the appellant’s request for newer DNA testing did not distinguish his claim from earlier petitions in a way sufficient to overcome legal bars or the presumption against timeliness. Additionally, the Court found the proposed testing would not significantly advance a claim of actual innocence, given the weight of the evidence at trial. The Court also concluded that no evidentiary hearing was required under these circumstances. View "HUSSEY v. STATE OF ARKANSAS" on Justia Law

An emergency-room physician and his girlfriend were driving on a highway when the girlfriend died under suspicious circumstances. The physician was the only person present with her at the time. He called 911 and told responders that she was having a seizure. Passersby and responders noted that the physician acted erratically and did not attempt to help. Medical personnel observed significant injuries to the girlfriend’s neck, and an autopsy concluded that she died from strangulation, though the defense’s expert disputed the cause. Text messages presented at trial revealed prior threats from the physician toward the girlfriend.The case was tried in the Chicot County Circuit Court before a jury, which heard conflicting testimony from expert witnesses about the cause of death. The defense argued that the cause was undetermined and that death could have resulted from medical intervention or natural causes. The State’s expert concluded the death was a homicide by strangulation. The jury found the physician guilty of second-degree murder and he was sentenced to thirty years’ imprisonment and fined. After trial, the defense moved for a new trial, alleging juror misconduct based on an affidavit from a juror. The trial court held a hearing, heard testimony from the relevant jurors, and denied the motion for a new trial, finding no credible evidence of misconduct.The Supreme Court of Arkansas reviewed the appeal and held that there was substantial evidence to support the conviction for second-degree murder, that the circuit court did not abuse its discretion in instructing the jury on second-degree murder as a lesser-included offense, and that there was no reversible error in denying the motion for a new trial based on alleged juror misconduct. The Supreme Court of Arkansas affirmed the conviction and vacated the Court of Appeals' opinion. View "TAIT v. STATE OF ARKANSAS" on Justia Law

The case concerns a man convicted of first-degree murder and a firearm enhancement following the fatal shooting of his business partner outside her home. The two had operated a food-truck business together, and on the day in question, the defendant was seen at the victim’s home with her truck. Several eyewitnesses, including members of the victim’s family and neighbors, testified about the events surrounding the shooting, identifying the defendant as present at the scene and as the person leaving in the victim’s truck after the shooting. After the crime, the defendant abandoned his business and job and evaded police for months, fleeing from law enforcement in both Texas and West Virginia before being apprehended. The Pulaski County Circuit Court, Seventh Division, presided over the defendant’s postconviction petition, which was filed under Arkansas Rule of Criminal Procedure 37.1. The defendant, initially pro se and later represented by counsel, alleged ineffective assistance of trial counsel on five grounds. At a hearing, the court considered evidence and testimony, including from trial counsel and an investigator. The court found that the defendant failed to show trial counsel’s performance was deficient under the standard established by Strickland v. Washington, and that no prejudice resulted from the alleged deficiencies. The court denied the petition. The Supreme Court of Arkansas reviewed the case. Applying the “clearly erroneous” standard, the court examined the trial court’s findings and the three ineffective-assistance claims raised on appeal: insufficient cross-examination of witnesses, failure to investigate the crime scene, and failure to obtain dashcam footage of the police chase. The Supreme Court concluded that the record showed effective cross-examination, that information about the scene was provided to the jury, and that counsel’s actions regarding the dashcam did not constitute ineffectiveness. The Supreme Court affirmed the lower court’s denial of postconviction relief. View "DORSEY v. STATE OF ARKANSAS" on Justia Law

The appellant was convicted by a jury in Johnson County, Arkansas, of capital murder, aggravated robbery, and theft of property. The evidence at trial included admissions by the appellant that he intended to rob the victim, that he stabbed her in the throat (which was the fatal wound), and that he stole her car and used her credit cards after her death. DNA evidence connected the appellant to the victim, and multiple witnesses, including the appellant’s sister and a friend, testified to his admissions and actions following the crime. After his conviction was affirmed on direct appeal by the Supreme Court of Arkansas, the appellant filed a petition for postconviction relief under Arkansas Rule of Criminal Procedure 37.1 in the Johnson County Circuit Court. He claimed ineffective assistance of counsel for failure to investigate a laptop allegedly containing exculpatory evidence and unidentified DNA found on a knife, asserted a violation under Brady v. Maryland for alleged suppression of the laptop, and argued that the prosecutor knowingly presented false testimony. The circuit court denied and dismissed the petition, finding that the claims were not supported by the record or were not cognizable in a Rule 37.1 proceeding. The Supreme Court of Arkansas reviewed the case and affirmed the circuit court’s denial and dismissal of the appellant’s petition. The court held that the appellant failed to present evidence supporting his claims, and his ineffective assistance of counsel argument lacked factual substantiation. The court also found the Brady claim and the argument regarding false testimony were either unsupported by evidence or not appropriate for postconviction relief under Rule 37.1. The Supreme Court of Arkansas concluded that the circuit court did not clearly err and affirmed its decision. View "OLIGER v. STATE OF ARKANSAS" on Justia Law