Justia Criminal Law Opinion Summaries

California Palms Addiction Recovery Campus, Inc., an Ohio rehabilitation center, and its owner, Sebastian Rucci, became the subjects of a federal criminal investigation in 2021. Pursuant to ex parte warrants issued by a magistrate judge, the FBI seized $603,902.89 from their accounts. Shortly thereafter, state agencies revoked the facility’s provider certification and terminated its Medicaid agreement. The plaintiffs filed a civil action in the United States District Court for the Northern District of Ohio, seeking the return of the seized funds and disclosure of the affidavits used to obtain the warrants, alleging constitutional defects and asserting a right to inspect the affidavits under the Fourth Amendment.The Government moved to stay the civil action, indicating its intent to pursue a civil forfeiture proceeding regarding the seized funds. After initiating the forfeiture case, the Government moved to dismiss the plaintiffs’ civil action, arguing that the statutory forfeiture process provided the appropriate remedy. The district court stayed the civil action pending resolution of the forfeiture case. In September 2024, the Government voluntarily dismissed the forfeiture proceeding and returned the funds with interest to the plaintiffs. The district court then ordered the plaintiffs to show cause why the civil action should not be dismissed as moot. Despite the plaintiffs’ argument that their claim for disclosure of the warrant affidavits remained unresolved, the district court dismissed the entire action as moot, reasoning that the plaintiffs had received the relief sought.On appeal, the United States Court of Appeals for the Sixth Circuit held that, while the claim for return of funds was moot, the claim for disclosure of the warrant affidavits was not. The court vacated the district court’s dismissal of the affidavit disclosure claim and remanded for further proceedings, holding that the existence of a live controversy over the disclosure request precluded dismissal for mootness. View "California Palms v. United States" on Justia Law

A native and citizen of the Dominican Republic, the petitioner was admitted to the United States as a lawful permanent resident in 2007. In 2022, he pleaded guilty in the United States District Court for the Middle District of Florida to conspiracy to commit money laundering under 18 U.S.C. § 1956(h). The judgment included a forfeiture order stating that at least $3,934,518 was obtained and laundered by the petitioner as a result of his participation in the conspiracy. In 2023, the Department of Homeland Security initiated removal proceedings, alleging that the petitioner was removable as an aggravated felon because his offense involved more than $10,000.An Immigration Judge found the petitioner removable as charged, relying on the conviction records, including the forfeiture order. The petitioner applied for cancellation of removal, but the Immigration Judge concluded he was ineligible due to the aggravated felony conviction. On appeal to the Board of Immigration Appeals, the petitioner argued that the forfeiture order did not meet the evidentiary standard required to establish that his conviction was an aggravated felony, as it did not specify the amount directly attributable to his conduct. The Board, applying the circumstance-specific approach endorsed by the Supreme Court in Nijhawan v. Holder, found that the forfeiture order was sufficient to establish that the funds involved exceeded $10,000 and dismissed the appeal.The United States Court of Appeals for the Fifth Circuit reviewed the Board’s decision de novo. The court held that an unrebutted forfeiture order entered solely against an alien, finding a specific amount of laundered funds attributable to the alien’s conduct of conviction, can constitute clear and convincing evidence that the amount of funds required by 8 U.S.C. § 1101(a)(43)(D) is met. The court denied the petition for review. View "Reyes v. Bondi" on Justia Law

A police officer in Casper, Wyoming, observed a pickup truck driven by Mark Davis traveling slowly and approaching a stop sign. The officer noticed Davis activated his right turn signal only shortly before stopping at the intersection, estimating the signal was turned on no more than twenty feet before the turn, rather than the statutorily required 100 feet. After stopping Davis, the officer discovered an open beer can and learned Davis’s license was suspended. A subsequent search of the vehicle revealed methamphetamine, marijuana, and drug paraphernalia. Davis was charged with felony possession of methamphetamine and felony possession with intent to deliver.Davis filed a motion to suppress the evidence, arguing the officer lacked reasonable suspicion for the traffic stop because he had activated his turn signal more than 100 feet before the turn. At the suppression hearing in the District Court of Natrona County, the officer testified about his training in estimating distances, and Davis’s expert witness presented calculations based on the dash cam video, but conceded uncertainty about Davis’s speed. The district court reviewed the video and testimony, ultimately finding the officer’s estimate credible and concluding the State met its burden to show reasonable suspicion for the stop. The court denied the motion to suppress, and Davis entered a conditional guilty plea, reserving his right to appeal.On appeal, the Supreme Court of Wyoming reviewed the district court’s denial of the suppression motion, deferring to its factual findings unless clearly erroneous and reviewing constitutional questions de novo. The Supreme Court held that, under the totality of the circumstances, the officer had reasonable suspicion to believe Davis violated the turn signal statute, justifying the stop. The district court’s findings were supported by the record, and the evidence obtained was admissible. The judgment was affirmed. View "Davis v. The State of Wyoming" on Justia Law

Police and medical personnel responded to a motel room in Casper, Wyoming, where they found Chance Arias deceased with injuries consistent with assault and strangulation. Surveillance footage showed James Mavigliano and Amber Cook entering and leaving the room multiple times. Mavigliano was later found nearby with a blue duffle bag containing a broken, bloody lamp, and he possessed the room key and drug paraphernalia. After being advised of his rights, Mavigliano admitted to killing Arias, describing a physical altercation that escalated to him striking Arias with a lamp and strangling him with the lamp’s cord. He acknowledged that Arias did not physically threaten or attack him.The State charged Mavigliano with second-degree murder and possession of a controlled substance. The case was tried before the District Court of Natrona County. At trial, the defense argued self-defense, and the jury was instructed that the State had to prove beyond a reasonable doubt that Mavigliano did not act in self-defense. The jury was also instructed on the requirement of unanimity for its verdict. The verdict form did not include a special interrogatory regarding self-defense, and defense counsel did not request one or object to the form. The jury found Mavigliano guilty of both charges, and he was sentenced accordingly.On appeal, Mavigliano challenged only his second-degree murder conviction, arguing that the district court committed plain error by not including a self-defense interrogatory on the verdict form. The Supreme Court of Wyoming held that there is no clear and unequivocal rule of law requiring a special self-defense interrogatory or unanimity instruction beyond the standard instructions given. The court found no plain error and affirmed the conviction. View "Mavigliano v. The State of Wyoming" on Justia Law

A man was convicted of three counts of sexual contact with a developmentally disabled adult neighbor, D.W., who functioned at the intellectual level of a seven-year-old. The incidents occurred during a Fourth of July celebration at the defendant’s home, involving inappropriate touching on a four-wheeler, on a hot tub, and behind a trailer. D.W. reported the incidents to his mother, who was his court-appointed guardian. The mother recorded a phone call in which the defendant made incriminating statements about the incidents. D.W. was later evaluated by a physician specializing in abuse of developmentally disabled individuals.The Circuit Court of the Second Judicial Circuit, Minnehaha County, presided over the trial. The court allowed D.W. to testify while holding a stuffed animal for comfort, over the defendant’s objection. The court denied the defendant’s motions for judgment of acquittal at the close of the State’s evidence and at the end of trial. The jury found the defendant guilty on all three counts. The defendant appealed, challenging the allowance of the stuffed animal, the sufficiency of the evidence, and two other issues not preserved for appeal: the physician’s testimony and the State’s cross-examination.The Supreme Court of the State of South Dakota reviewed the case. It held that the circuit court did not abuse its discretion in allowing D.W. to testify with a stuffed animal, as courts have broad authority to manage witness testimony and accommodations. The Supreme Court also found no plain error in the State’s cross-examination or the physician’s testimony, and concluded that sufficient evidence supported the convictions. The Supreme Court affirmed the convictions and all rulings of the circuit court. View "State v. Richter" on Justia Law

Soloman Longchase was charged with multiple offenses, including aggravated assault (domestic), aggravated kidnapping, grand theft, interference with emergency communication, and false impersonation to deceive law enforcement, stemming from incidents on August 20, 2022. After the initial complaint and indictment, Longchase was held in the Hughes County Jail on unrelated charges. He was granted a medical furlough but failed to return, resulting in an escape charge and a period as a fugitive until his rearrest in December 2023. He later appeared in court for the Hyde County charges, was appointed counsel, and ultimately entered a plea agreement to plead guilty to grand theft and simple assault, with other charges dismissed.The Circuit Court of the Sixth Judicial Circuit, Hyde County, presided over the case. Longchase moved to dismiss the indictment, alleging a violation of his constitutional right to a speedy trial. The circuit court denied the motion after applying the Barker v. Wingo factors. At sentencing, the court ordered Longchase to reimburse the county for court-appointed attorney fees, finding he had the ability to work and pay after release from prison. Longchase objected, arguing the court was required to make specific findings about his ability to pay and that recoupment was unconstitutional given his current financial status.The Supreme Court of the State of South Dakota reviewed the case. It held that Longchase’s unconditional guilty plea waived his right to appeal the alleged speedy trial violation, as the right to a speedy trial is not a jurisdictional defect that survives a guilty plea. The court also held that the circuit court’s order requiring reimbursement of attorney fees did not violate Longchase’s constitutional rights to counsel or due process, as he was afforded counsel at all critical stages and had a meaningful opportunity to contest the recoupment order. The Supreme Court affirmed the circuit court’s rulings. View "State v. Longchase" on Justia Law

A man was charged with multiple offenses, including aggravated sexual assault and aggravated assault, after an incident in which a woman alleged he raped her at gunpoint in his car. At trial, the woman and the defendant gave conflicting accounts: she described a violent, non-consensual encounter involving threats and physical force, while he claimed the encounter was consensual. Physical evidence, including injuries documented by a sexual assault nurse examiner (SANE), and corroborating witness testimony supported the woman’s account. The jury convicted the defendant of aggravated sexual assault and aggravated assault, and he was sentenced to concurrent prison terms.Following his conviction, the defendant pursued posttrial motions in the Third District Court, including claims of a Brady violation and ineffective assistance of trial counsel. The trial court denied these motions after an evidentiary hearing. On direct appeal, the Utah Court of Appeals affirmed the convictions, and the Supreme Court of the State of Utah later affirmed on certiorari, rejecting arguments related to jury instructions and the alleged Brady violation.The defendant then filed a petition for postconviction relief, later amended to include claims of due process violations, the right to present a complete defense, and ineffective assistance of both trial and appellate counsel. The State moved for summary judgment, and the defendant filed a combined opposition and cross-motion for summary judgment. The postconviction court granted the State’s motion, struck the defendant’s cross-motion as procedurally improper, and found the defendant’s claims either procedurally barred or lacking in prejudice.On appeal, the Supreme Court of the State of Utah affirmed the postconviction court’s grant of summary judgment for the State and its decision to strike the defendant’s cross-motion. The Court clarified that while postconviction petitioners may not combine a response and a motion in a single document, nothing in the Post-Conviction Remedies Act or Utah Rules of Civil Procedure prohibits petitioners from filing their own motions for summary judgment. View "Newton v. State" on Justia Law

The case concerns a defendant who pleaded guilty to being a felon in possession of a firearm and ammunition after he and others entered a victim’s home, threatened him with a firearm, and stole his truck. When apprehended, law enforcement found ammunition on his person and a firearm in the stolen vehicle. The defendant had three prior Florida state convictions for delivery of cocaine, each involving small amounts sold to a confidential informant in early 2017.The United States District Court for the Middle District of Florida sentenced the defendant to 180 months in prison, applying the Armed Career Criminal Act (ACCA) enhancement. The court determined that his three Florida convictions for delivery of cocaine qualified as “serious drug offenses” under ACCA, using the version of Florida law in effect at the time of his convictions in August 2017, which excluded ioflupane from the definition of cocaine, thus matching federal law.On appeal, the United States Court of Appeals for the Eleventh Circuit reviewed whether the ACCA enhancement was properly applied. The appellate court held that, under Supreme Court precedent, the relevant comparison for the categorical approach is between the state law in effect at the time the defendant committed the state offenses and the federal drug schedules in effect at that time. In early 2017, Florida law defined cocaine to include ioflupane, while federal law did not, making Florida’s definition broader than the federal definition. Because Florida’s saving provision prevented the later narrowing of the law from applying retroactively, the mismatch remained. The Eleventh Circuit concluded that the defendant’s Florida convictions did not qualify as ACCA predicates, vacated the sentence, and remanded for resentencing without the ACCA enhancement. View "USA v. Miller" on Justia Law

In March 2023, a New York State grand jury indicted a former President on thirty-four counts of falsifying business records in the first degree. The indictment alleged that he orchestrated a scheme to influence the 2016 presidential election by directing his personal lawyer to pay $130,000 to an adult film star to prevent disclosure of an alleged sexual encounter. The payments were disguised as legal fees in business records. After arraignment, the defendant sought to remove the case to federal court under the federal officer removal statute, arguing the conduct was within the color of his office and involved federal defenses. The federal district court remanded the case to state court, finding the prosecution fell outside the scope of federal officer removal jurisdiction. A state court jury subsequently convicted the defendant on all counts.After conviction but before sentencing, the United States Supreme Court issued a decision in Trump v. United States, holding that the President is absolutely immune from criminal prosecution for conduct within his exclusive constitutional authority and that evidence of immunized official acts is inadmissible even when an indictment alleges only unofficial conduct. The defendant then sought leave to file a second, untimely notice of removal in federal court, arguing that the Supreme Court’s decision provided new grounds for removal and established good cause for the delay. The United States District Court for the Southern District of New York denied leave, concluding that good cause had not been shown and that the hush money payments were private, unofficial acts.The United States Court of Appeals for the Second Circuit reviewed the district court’s denial. The Second Circuit held that the district court had not adequately considered issues relevant to the good cause inquiry, including the impact of the Supreme Court’s decision and whether evidence admitted at trial related to immunized official acts. The Second Circuit vacated the district court’s order and remanded for reconsideration of the motion for leave to file a second notice of removal, instructing the district court to address these issues. View "New York v. Trump" on Justia Law

In October 2022, a man crashed his car into a parked vehicle in southeast Washington, D.C. After the collision, the car’s owner confronted him, and as police arrived, the man fled on foot. Officers pursued and apprehended him, discovering a gun with a large-capacity magazine under a vehicle along his escape route and another large-capacity magazine with ammunition inside his car. He was charged with several firearm-related offenses, including possession of a large-capacity ammunition feeding device and unlawful possession of ammunition.The Superior Court of the District of Columbia denied the defendant’s motions to dismiss the large-capacity magazine charges on Second Amendment grounds and to suppress the evidence found at the scene, ruling that the search and seizure were justified. After a jury trial, he was convicted of one count of possession of a large-capacity ammunition feeding device and one count of unlawful possession of ammunition, both based on the magazine found in his car. He was acquitted of other charges. The defendant appealed, challenging the denial of suppression, the sufficiency of the evidence for the large-capacity magazine conviction, the lack of a jury instruction on knowledge, and the constitutionality of the statute.The District of Columbia Court of Appeals reviewed the case. After oral argument, the government moved to vacate the large-capacity magazine conviction due to a change in its position on the statute’s constitutionality, which the court granted. The court affirmed the denial of suppression and upheld the unlawful possession of ammunition conviction, holding that the officers’ entry into the car to seize the magazine was justified under the automobile exception to the warrant requirement, as they had probable cause to believe the car contained evidence of criminal activity. The case was remanded for further proceedings. View "Miller v. United States" on Justia Law