Justia Criminal Law Opinion Summaries

In a joint trial, Markeese Mitchell, Pedro Ortiz, and Terrance Pabon were convicted of second-degree murder. Years later, they moved to interview a juror, alleging bias and concealment of material information during jury selection. The motion was denied, and the convictions were affirmed on appeal. Subsequently, the defendants filed motions for a new trial, citing additional evidence of the same juror's alleged bias. The motion judge conducted an evidentiary hearing, where the juror testified, and then denied the new trial motions. The defendants also moved to disqualify the trial judge, arguing a conflict of interest due to the judge's professional relationship with the prosecutor from their original trial, who had since become a Superior Court judge. This motion was also denied.The Appeals Court affirmed the orders denying the motions for a new trial and for disqualification. The Supreme Judicial Court granted further appellate review. The defendants argued that they were entitled to a new trial because the juror failed to provide an honest response to a material question during empanelment, and an honest response would have provided valid grounds for a challenge for cause. They also argued that the trial judge should have been disqualified due to a conflict of interest.The Supreme Judicial Court concluded that the trial judge did not abuse her discretion in denying the motions for a new trial or the motion for disqualification. The Court found that the juror's inaccurate answer was not dishonest and did not demonstrate bias. The Court also found that the trial judge's professional relationship with the former prosecutor did not create an appearance of partiality. Therefore, the orders denying the motions for a new trial and for disqualification were affirmed. View "Commonwealth v. Mitchell" on Justia Law

The defendant was convicted of unlawful restraint in the second degree, sexual assault in the fourth degree, attempt to commit sexual assault in the third degree, and sexual assault in the third degree. The charges stemmed from an incident where the defendant allegedly assaulted the victim, C, in his home. C testified that the defendant made unwanted advances, restrained her, and sexually assaulted her. The defendant argued that C fabricated the story due to a rent dispute between the defendant and C's mother, K.The trial court found the defendant guilty on all charges, and the Appellate Court affirmed the conviction. The defendant appealed, claiming that the prosecutor's remarks during rebuttal closing argument were improper and deprived him of a fair trial. Specifically, the prosecutor listed common defenses in criminal cases and referred to the "nuts and sluts" defenses in sexual assault cases, suggesting that C would have to be "nuts" to fabricate her story.The Supreme Court of Connecticut reviewed the case and determined that the prosecutor's use of the phrase "nuts and sluts" was improper as it appealed to the jurors' emotions and diverted their attention from the evidence. The court also found that the prosecutor's listing of defenses was improper because it was unrelated to the evidence presented at trial. However, the court concluded that these improprieties did not deprive the defendant of a fair trial.The court applied the factors from State v. Williams to assess the impact of the improprieties. It found that the prosecutor's statements were not severe, were infrequent, and the state's case was relatively strong. The court also noted that defense counsel did not object to the statements or request curative instructions. As a result, the Supreme Court of Connecticut affirmed the judgment of the Appellate Court. View "State v. Sullivan" on Justia Law

On July 17, 2021, Whitefish Police Officer Chase Garner confronted Paul Kermit Gysler for urinating in public. The encounter escalated, resulting in Gysler assaulting Officer Garner. Gysler claimed self-defense, asserting that Officer Garner approached him aggressively. The State charged Gysler with felony assault on a peace officer. Gysler was arrested and released on bond but was later re-arrested for unrelated charges, leading to multiple delays in his trial.The Eleventh Judicial District Court issued an arrest warrant for Gysler for violating his release conditions. The court ordered a competency evaluation due to concerns about Gysler's mental fitness, which delayed the trial further. Gysler's trial was eventually set for December 12, 2022. He filed a motion to dismiss for lack of a speedy trial, which the court denied. The jury found Gysler guilty of assaulting a peace officer.The Supreme Court of the State of Montana reviewed the case. The court analyzed the four factors of a speedy trial claim: length of delay, reasons for delay, the accused’s response to the delay, and prejudice to the accused. The court found that most of the delay was institutional and not due to the State's negligence. The court concluded that Gysler did not suffer oppressive pretrial incarceration, undue anxiety, or impairment of his defense.The court also reviewed the jury instructions. It held that the District Court did not err in instructing the jury on resisting arrest and justified use of force, as the instructions were supported by the evidence and did not nullify Gysler's self-defense claim. The court affirmed the District Court's judgment, finding no violation of Gysler's right to a speedy trial and no error in the jury instructions. View "State v. Gysler" on Justia Law

Joseph Edward Knowles, at age 16, and his girlfriend planned to steal marijuana from Megan Meriwether. During the theft, a fight ensued, and Knowles stabbed Meriwether, resulting in her death. Knowles was charged as an adult with deliberate homicide and tampering with evidence. He pled guilty to deliberate homicide under a plea agreement, and the tampering charge was dismissed. The District Court sentenced him to 60 years in prison without parole restrictions.Knowles appealed the original judgment, which did not reflect his status as a criminally convicted youth under the Criminally Convicted Youth Act (CCYA). The Montana Supreme Court ordered the District Court to amend the judgment to include CCYA provisions, requiring the Department of Corrections (DOC) to submit status reports every six months and for the court to review Knowles’s sentence before he turned 21. However, the District Court did not receive this order until Knowles was 22, and no status reports were filed during the statutory period.The Montana Supreme Court reviewed whether the District Court abused its discretion by reimposing Knowles’s original sentence without the benefits of the CCYA. The Court found that the District Court and DOC failed to follow the CCYA, denying Knowles the rehabilitative opportunities intended by the Act. The Court held that the District Court abused its discretion by determining Knowles had not been substantially rehabilitated without the benefit of ongoing status reports and meaningful rehabilitative programs.The Montana Supreme Court reversed the District Court’s decision and remanded the case, instructing the DOC and District Court to apply the CCYA provisions. Knowles is allowed to request a CCYA sentence review hearing within two years of the opinion date. View "State v. Knowles" on Justia Law

In July 2022, Robert Brady was charged with felony Assault with a Weapon after an incident involving his wife, stepdaughter, and stepdaughter's husband. Brady allegedly pointed a shotgun at his stepdaughter's husband and threatened to kill him. Brady appeared intoxicated and claimed self-defense. He was released on the condition of no contact with the victims. In August 2022, Brady pleaded not guilty, and the case proceeded to trial. In December 2022, the State petitioned to revoke Brady's release for noncompliance with alcohol monitoring conditions, and he was jailed in January 2023.Brady and the State then signed a plea agreement where Brady would plead guilty in exchange for a three-year deferred sentence recommendation. The agreement restricted Brady from seeking early discharge until two years after sentencing. At the change of plea hearing, Brady pleaded guilty, and the court accepted the plea. However, the court later expressed concerns about following the plea agreement due to Brady's violations and lack of accountability. The prosecutor's comments during sentencing suggested the plea deal was too lenient, leading the court to impose a five-year deferred sentence with additional conditions.The Montana Supreme Court reviewed the case and found that the prosecutor breached the plea agreement by undermining the recommended sentence. The court held that a district court does not have unilateral authority to restrict a defendant's right to seek early termination of a sentence under Montana law. However, a defendant may agree to such a restriction in a plea agreement. The court vacated Brady's sentence and remanded for resentencing before a different judge, directing specific performance of the plea agreement in its entirety. View "State v. Brady" on Justia Law

In this criminal case, the defendants, Andre Dimitri Richee and Lee Albert Mooring, were charged with the murder of Daniel Gonzalez and the attempted murders of A.P. and D.M. The incident occurred in September 2020, when a white sedan with tinted windows approached a group of people, including the victims, in an alley. After a brief exchange, the car returned, and shots were fired from the vehicle, resulting in Gonzalez's death and injuries to A.P. and D.M. The prosecution presented evidence, including witness identifications, surveillance footage, and statements made by the defendants, to establish their involvement in the crime.The Superior Court of Riverside County found the defendants guilty of first-degree murder with special circumstances and two counts of attempted murder. The jury also found true the special circumstance allegation that the murder was committed by discharging a firearm from a vehicle. The court sentenced both defendants to life in prison without the possibility of parole, plus additional prison terms. The defendants appealed, arguing that the trial court committed instructional errors and that the evidence was insufficient to support their convictions.The Court of Appeal of the State of California, Fourth Appellate District, Division Three, reviewed the case. The court found that the trial court had indeed committed instructional errors by instructing the jury on invalid theories of murder and attempted murder under the natural and probable consequences doctrine and by failing to instruct on the elements of the special circumstance charge. The appellate court concluded that these errors undermined the defendants' rights to a fair trial.As a result, the Court of Appeal reversed the defendants' convictions for attempted murder but affirmed their convictions for murder and the special circumstance findings. The court remanded the case for further proceedings, including the possibility of retrial for the attempted murder charges and resentencing. The appellate court also directed the trial court to impose any remaining victim restitution amount jointly and severally upon resentencing. View "People v. Richee" on Justia Law

Sonny Ramdeo, while working as a payroll director for Promise Healthcare, recommended the company hire PayServ Tax, which he falsely claimed was a subsidiary of Ceridian Corporation. In reality, PayServ was Ramdeo’s own company, and he diverted over $20 million from Promise to fund a charter airline service. After Promise’s auditors discovered discrepancies, Ramdeo was arrested and pled guilty to wire fraud and money laundering. He was sentenced to twenty years in prison, followed by three years of supervised release, and ordered to pay $21,442,173 in restitution.Ramdeo challenged his conviction and restitution amount on direct appeal, which was unsuccessful. He then sought a writ of audita querela to contest the restitution amount, which the district court recharacterized as a petition for coram nobis and subsequently denied. The Eleventh Circuit declined to address the merits of his claim. Ramdeo also filed a 28 U.S.C. § 2255 petition, which the district court denied as frivolous and meritless. The Eleventh Circuit affirmed this decision. Ramdeo later filed a pro se petition for a writ of error coram nobis, arguing ineffective assistance of counsel, prosecutorial misconduct, and new financial evidence. The district court denied the petition, stating that prisoners in federal custody are ineligible for coram nobis relief.The United States Court of Appeals for the Eleventh Circuit reviewed the case and determined that being in custody does not categorically bar a petitioner from seeking coram nobis relief for non-custodial aspects of their sentence, such as restitution. The court vacated the district court’s order and remanded the case for further proceedings, emphasizing that coram nobis is an extraordinary remedy available when no other remedy is available, and the petitioner presents sound reasons for not seeking relief earlier. View "Ramdeo v. United States" on Justia Law

The defendant, Laquawn Lewis, was charged with attempted murder, robbery, assault, and obstruction of governmental administration. Leading up to his trial, Lewis expressed dissatisfaction with his appointed counsel and filed various pro se motions. He eventually requested to represent himself, stating his intention to proceed pro se. The court denied his request without conducting the required inquiry into whether his decision was knowing, voluntary, and intelligent.At trial, Lewis reiterated his desire to represent himself, but the court again denied his request and proceeded with jury selection. Lewis later pleaded guilty to avoid a potential life sentence based on an incorrect assumption about his status as a persistent felony offender. After realizing the error, defense counsel moved to withdraw the guilty plea, which the court granted. Lewis renewed his request to represent himself, but the court deferred the decision until the trial date and ultimately denied it again. Lewis was convicted of all charges except attempted murder and sentenced to 25 years' incarceration and 5 years' post-release supervision.The Appellate Division affirmed the judgment, holding that Lewis's requests to proceed pro se were not unequivocal and that his legal sufficiency argument was unpreserved and without merit. A Judge of the Court of Appeals granted Lewis leave to appeal.The New York Court of Appeals concluded that the trial court violated Lewis's constitutional right to self-representation by denying his unequivocal request to proceed pro se without the requisite inquiry. The court held that Lewis's request was clear and timely, and the trial court's failure to conduct an inquiry warranted a new trial. The court also found that Lewis's legal sufficiency argument was unpreserved. Consequently, the Court of Appeals reversed the Appellate Division's order and granted Lewis a new trial. View "People v Lewis" on Justia Law

Lawrence Davonn Foye was placed on court-supervised parole after being convicted of fleeing in a vehicle with reckless indifference. His parole conditions included not violating any laws, avoiding disreputable persons, and abstaining from drug use. In January 2023, his probation officer filed a petition to revoke his parole, alleging three violations: using marijuana, being charged with first-degree murder, and associating with a disreputable person. Following a hearing, the Circuit Court of Kanawha County revoked his parole and imposed the underlying sentence.The Circuit Court found that the State presented sufficient evidence to support the parole violations. Detective Adkins testified about the murder investigation, corroborating information from a cooperating witness with cell phone data and video footage. The court also noted that Foye did not contest the allegations of drug use and associating with a disreputable person. The court applied the "reasonable cause" standard from West Virginia Code § 62-12-10(a)(1) to revoke Foye's parole.The Supreme Court of Appeals of West Virginia reviewed the case and affirmed the Circuit Court's decision. The court clarified that the standard of proof for a final parole or probation revocation hearing under West Virginia Code § 62-12-10(a)(1) is proof by a preponderance of the evidence. The court found that the State met this standard by presenting sufficient evidence of all three parole violations. The court also addressed the procedural due process requirements, ensuring that Foye's rights were protected during the revocation process. View "State v. Foye" on Justia Law

Edwin Leo Brown was indicted in October 2016 on four counts of possession with intent to distribute cocaine base and one count of being a felon in possession of a firearm. The government had evidence of Brown selling cocaine base and discovered a firearm upon his arrest. Brown faced up to 90 years in prison. His attorney, Frank Harper, initially advised him that he was likely facing up to 120 months’ imprisonment and presented two plea agreements limiting his prison exposure to ten years. Brown, skeptical of Harper’s advice, did not trust him and Harper withdrew as counsel. Brett Wentz then became Brown’s attorney and erroneously advised him that his sentencing exposure would be the same whether he accepted a plea deal or not. Brown rejected the plea offers and later pleaded guilty to all counts, receiving a 210-month sentence.The United States District Court for the Eastern District of North Carolina found that Brown’s attorney performed deficiently but concluded that Brown failed to demonstrate he was prejudiced by his attorney’s advice. The magistrate judge recommended denying Brown’s motion to vacate his sentence, stating that Brown presented no contemporaneous evidence to support his claim that he would have accepted the plea agreement if properly advised. The district court adopted this recommendation and denied Brown’s motion.The United States Court of Appeals for the Fourth Circuit reviewed the case de novo and found that the district court erred in applying the standard from Lee v. United States, which concerns accepted plea deals, to Brown’s case involving a rejected plea deal. The Fourth Circuit held that Brown demonstrated a reasonable probability that he would have accepted the plea offer if properly advised, given the significant disparity between the plea offer and the sentence he received. The court reversed the district court’s denial of relief, remanded the case, and required the government to re-offer Brown the same plea agreements. View "United States v. Brown" on Justia Law