Justia Criminal Law Opinion Summaries

A driver in Lake Havasu City rear-ended a Jeep that was stopped at a red light, causing the Jeep to be pushed through the intersection and resulting in the death of one of its passengers. The driver’s vehicle also continued through the intersection while the light was red. Prosecutors charged the driver under Arizona’s enhanced penalty statute, which criminalizes certain traffic violations—including running a red light—if those violations result in an accident causing serious injury or death.After a bench trial, the Lake Havasu Consolidated Court found the driver guilty, reasoning that the entire sequence of events—from the rear-end collision to the vehicles coming to rest—constituted a single “accident” under the statute. On appeal, the Mohave County Superior Court reversed the conviction, concluding that the driver’s red-light violation did not cause the fatal accident because the collision occurred before the vehicle entered the intersection and thus before a red-light violation was committed. The State sought further review, and the Arizona Court of Appeals sided with the State, interpreting the statute to cover a continuous chain of events, so long as the accident ultimately resulted from failing to stop at the red light.The Supreme Court of the State of Arizona reviewed the case to clarify the statute’s scope. The court held that a violation of the red-light statute occurs only when a driver enters an intersection against a red light. Therefore, the enhanced penalty does not apply to an accident that occurs before the driver enters the intersection, even if the vehicle subsequently runs the red light. The court vacated the court of appeals' opinion and affirmed the superior court’s order directing an acquittal, holding that the enhanced penalty statute requires the red-light violation to precede the accident causing injury or death. View "STATE OF ARIZONA v GORDON" on Justia Law

The defendant, an adult male in his fifties, was accused of engaging in unlawful sexual contact with his twelve-year-old great-niece while she was staying overnight at his home in October 2020. The victim disclosed the incident to her mother about a year later after family members encouraged her to speak up due to concerns arising from accusations the defendant had made against the victim’s cousin. The matter was reported to law enforcement and later discussed in a forensic interview. The defendant was subsequently indicted and proceeded to a jury trial.During the trial in the Cumberland County Unified Criminal Docket, significant evidentiary disputes arose. The State sought to introduce testimony regarding a subsequent incident in which the defendant allegedly offered a sex toy to the victim and another individual, arguing its relevance to intent and the relationship between the parties. The defense objected, citing prejudice and late disclosure, and initially, the trial court excluded the evidence but left open the possibility of reconsideration. As the trial progressed and new lines of questioning emerged, the court ultimately allowed this evidence, finding no unfair prejudice. The defense also attempted to introduce evidence that the defendant had threatened the victim’s cousin, theorizing it would demonstrate a motive to fabricate the allegations. The court excluded this testimony, finding it irrelevant because there was no evidence the victim knew of the threats or that her family conspired to fabricate the allegations.The jury found the defendant guilty, and the court imposed a sentence of eight years, with a portion suspended and a probation period. On appeal, the Maine Supreme Judicial Court held that the trial court acted within its discretion in admitting the evidence of the subsequent sexual behavior and did not err in excluding the evidence of threats toward the cousin due to lack of relevance. The judgment of conviction was affirmed. View "State of Maine v. Cardona" on Justia Law

After pleading guilty to felony child neglect, the defendant was sentenced to five years’ imprisonment with three years suspended, credit for 375 days already served, supervised probation, and restitution. Following his release, the State alleged that the defendant violated multiple conditions of his probation. At a probation revocation hearing, the defendant waived his right to counsel and admitted the violations, leading the district court to revoke his probation. The court orally stated the defendant would receive credit for two years plus the time he spent in custody after being arrested on the probation violation warrant, which amounted to twenty-four days.The written order issued after the revocation hearing, however, erroneously recorded the credit for time served as “3 years and 34 days” instead of the correct “2 years and 24 days.” The State moved to correct this mistake under North Dakota Rule of Criminal Procedure 36, arguing it was a clerical error that conflicted with the court’s oral pronouncement. The District Court of McHenry County granted the State’s motion, found the original written order contained a clerical error, and issued an amended order reflecting the proper credit. The defendant appealed, arguing that the correction improperly reduced his credit for time served and conflicted with the court’s oral pronouncement. He also asserted his constitutional right to counsel was violated when the court did not appoint an attorney to represent him in the Rule 36 proceedings.The Supreme Court of North Dakota affirmed the district court’s orders. It held that the correction was a permissible exercise of the court’s discretion under Rule 36 to remedy a clerical error in the judgment so that it accurately reflected the oral pronouncement at the revocation hearing. The court also concluded that the defendant’s constitutional right to counsel was not violated because the correction of a clerical error under Rule 36 is not a critical stage of the prosecution. View "State v. Jaeger" on Justia Law

In this case, a man moved in with his girlfriend and her children, including twin daughters who referred to him as their stepfather. After the man lived with the family, one of the twins, M.R., disclosed that he repeatedly sexually abused her when she was six and seven years old. She described being taken to the basement while her mother was asleep, having various sexual acts performed on her, and being shown explicit videos. She did not initially report the abuse due to fear and threats from the man. Eventually, she told her grandmother, which led to a police and medical investigation, forensic interviews, and the discovery of pornography and sex-related items in the home. The man denied the allegations and was indicted on multiple charges. Though the children gave inconsistent statements in family court, at the criminal trial both confirmed the abuse and explained their earlier denial was out of fear and misunderstanding.A Jefferson County jury acquitted the defendant of intimidating a participant in a legal proceeding but convicted him of three counts of first-degree sodomy, two counts of first-degree sexual abuse, and one count of distributing obscene matter to a minor. The Jefferson Circuit Court sentenced him to twenty years in prison, adopting the jury’s recommendation.On appeal to the Supreme Court of Kentucky, the defendant argued that the trial court erred by admitting certain testimony and other acts evidence, denying his motion for a directed verdict on the obscene matter charge, and refusing to instruct the jury on lesser-included offenses. The Supreme Court of Kentucky rejected all arguments. It held that the challenged testimony was properly admitted, the evidence was sufficient to support the obscene matter conviction, the other acts evidence was admissible with proper notice, and the trial court properly declined to instruct on lesser-included offenses. The court affirmed the conviction and sentence. View "MENDEZ V. COMMONWEALTH OF KENTUCKY" on Justia Law

The case involves an incident in September 2020 where Hartsfield met B.B. at a hotel, and B.B. later accused Hartsfield of rape and assault. Both individuals were interviewed by police, and these interviews were recorded on body cameras. The key evidentiary dispute centered on a portion of the body camera video in which a police officer stated his opinion about whether B.B. was telling the truth regarding her allegations against Hartsfield.The Fayette Circuit Court denied the Commonwealth’s motion in limine, which sought to exclude the officer’s recorded opinion about B.B.’s credibility. The court ruled that the entire body camera video was admissible, reasoning that the officer’s statements provided context rather than being offered for the truth of the matter asserted. The Commonwealth appealed this decision. The Kentucky Court of Appeals reversed the trial court, holding that the officer’s comments on the alleged victim’s credibility were inadmissible and that the trial court erred in ordering the wholesale admission of the video.Upon discretionary review, the Supreme Court of Kentucky affirmed the Court of Appeals’ decision. The Supreme Court held that it is generally improper for one witness to opine on the veracity of another witness, whether directly or indirectly, and that such opinions are within the exclusive province of the jury. The Court distinguished prior precedent, concluding that the officer’s statements at issue were not part of an interrogation technique but were testimonial and inadmissible. The Supreme Court also clarified that video evidence must be limited to admissible portions rather than admitted in its entirety if it contains impermissible content. The Court remanded the case for the trial court to grant the Commonwealth’s motion in limine. View "HARTSFIELD V. COMMONWEALTH OF KENTUCKY" on Justia Law

The defendant was charged with simple assault following an incident in April 2022. Throughout the proceedings, he was represented by a series of court-appointed attorneys. The first attorney was replaced due to a change in employment. The next two attorneys withdrew, one citing a breakdown in the attorney-client relationship and the other a conflict of interest. Each time, a new attorney was appointed. Upon the withdrawal of the fourth appointed attorney, due to a deteriorated attorney-client relationship and the defendant’s insistence on pursuing an unethical defense, the defendant was informed by court order that no further counsel would be provided at public expense. He was served with the withdrawal orders but was not present at every hearing. At a pretrial hearing the day before trial, the defendant again requested appointed counsel, but the court required him to proceed pro se if he had not retained a lawyer by the next day. The defendant represented himself at trial and was convicted.The District Court of Burleigh County, South Central Judicial District, presided over the pretrial proceedings, withdrawals, and trial. The court concluded that, given the repeated breakdowns with counsel and explicit orders, the defendant’s conduct constituted the functional equivalent of a voluntary waiver of his right to counsel, and therefore required him to proceed without appointed counsel.Upon review, the Supreme Court of North Dakota found that, although the defendant’s actions amounted to a functional waiver of his right to counsel, the record did not establish that such waiver was made knowingly and intelligently. Specifically, the court noted the absence of a warning or explanation to the defendant regarding the dangers and disadvantages of self-representation prior to his final attorney’s withdrawal. The Supreme Court of North Dakota reversed the conviction and remanded the case for further proceedings, holding that the defendant’s waiver of counsel was not knowing and intelligent as required by law. View "State v. Hoff" on Justia Law

An Ohio State Highway Patrol trooper, C.G., was directing traffic at an intersection where the traffic light was out, wearing a reflective vest and visible during daylight hours. Edward Balmert, while driving, struck C.G. as she was directing traffic, causing her serious injuries. At the scene, Balmert provided a urine sample, which showed marijuana metabolite levels far exceeding the legal limit. Balmert admitted regular use of hemp products, including that morning, and failed field sobriety tests administered by certified drug-recognition experts.The case proceeded as a bench trial in the Lorain County Court of Common Pleas. Balmert was charged with four counts, including aggravated vehicular assault and operating a vehicle with a prohibited concentration of marijuana metabolites. The trial court denied his motion for acquittal and found him guilty of aggravated vehicular assault and operating with a prohibited metabolite concentration but acquitted him on other charges. He was sentenced to prison. On appeal, the Ninth District Court of Appeals affirmed the aggravated vehicular assault conviction, holding that sufficient evidence supported the finding of proximate causation between Balmert’s violation and C.G.’s injuries.The Supreme Court of Ohio reviewed whether proximate cause is a separate required element in aggravated vehicular assault cases based on driving with a prohibited concentration of marijuana metabolites, and whether the evidence supported such a finding here. The court held that proximate cause is a distinct element that must be proven beyond a mere violation of the statute. Here, the evidence—viewed favorably to the prosecution—showed that causing injury was a foreseeable consequence of driving with excessive marijuana metabolites. Thus, the court affirmed the conviction and the judgment of the Ninth District Court of Appeals. The appellant’s other propositions of law were dismissed as improvidently accepted. View "State v. Balmert" on Justia Law

In 1991, a jury convicted an individual of rape, sexual abuse, and abduction based on the testimony of the victim, who identified her attacker after encountering him twice following the assault. The incident occurred outdoors, and the victim described being attacked by a teenager whom she did not know. Physical evidence was collected at the hospital, but initial forensic testing at the time found no semen or foreign hairs linking the defendant to the crime. Despite the lack of biological evidence, the victim’s identification was central to the prosecution’s case, and the jury returned a guilty verdict.After exhausting direct appeals, the convicted individual sought post-conviction DNA testing decades later, alleging that advances in technology could yield exculpatory results. DNA testing was conducted on the biological evidence collected from the victim, including her underwear and swabs. The new tests found no male DNA on most items and excluded the defendant as a contributor to a partial DNA mixture found on the underwear. The individual then petitioned the Supreme Court of Virginia for a writ of actual innocence, arguing both the absence of his DNA and new non-biological evidence, including a declaration about the victim’s cognitive health and research on eyewitness identification.The Supreme Court of Virginia reviewed the petition under the statutory standard requiring the petitioner to show, by a preponderance of the evidence, that no rational factfinder would have found proof of guilt beyond a reasonable doubt in light of the new evidence. The Court held that the new DNA results did not definitively link or exclude the defendant from the crime and that the non-biological evidence was speculative and collateral. The Court concluded that the petitioner failed to meet the statutory burden and dismissed the petition for a writ of actual innocence. View "In Re: Hargrove" on Justia Law

The case concerns a defendant who pleaded guilty in 2012 to multiple sex offenses involving his minor children. He was sentenced to ten years in state prison followed by ten years of probation, with mandatory global positioning system (GPS) monitoring as a condition of probation under Massachusetts law. The statute required GPS monitoring for the entirety of his probation, but at the time of sentencing, no specific exclusion zones were established. After serving his prison sentence and two years of probation with GPS monitoring, the defendant sought relief from the GPS monitoring condition, arguing that it was unreasonable and unconstitutional, particularly due to its ten-year duration.After the Supreme Judicial Court’s decision in Commonwealth v. Feliz, which required individualized judicial findings regarding the reasonableness of GPS monitoring as a probation condition, the defendant filed a motion in the Superior Court for such an individualized assessment. The Superior Court judge denied the motion, finding that the Commonwealth had shown continued GPS monitoring was reasonable, based in part on the defendant’s classification as a level three sex offender and the victims’ statements about ongoing harm. However, the judge did not make findings regarding the reasonableness of the specific ten-year duration of GPS monitoring.The Supreme Judicial Court of Massachusetts reviewed the case on direct appellate review. The Court held that a judge must consider the duration of GPS monitoring in evaluating its reasonableness under the Massachusetts Declaration of Rights. The holding clarified that a judge may only impose GPS monitoring for a duration found to be reasonable, even if that period is less than the statutory term of probation. Because the Superior Court judge did not evaluate the ten-year duration, the Supreme Judicial Court vacated the order denying the defendant’s motion and remanded for further proceedings consistent with its opinion. View "Commonwealth v. Arnold" on Justia Law

The case involved a defendant who, while driving a sport utility vehicle (SUV) without a license, struck and fatally injured a pedestrian at an intersection in Waterbury, Connecticut. The defendant fled the scene without stopping. Several miles away, after the SUV broke down and partially blocked a residential driveway, the defendant, with the help of the homeowner and a taxi driver, pushed the damaged SUV into the driveway, leaving it at the front of other vehicles with its damaged front end fully visible from the street. The defendant did not attempt to hide the SUV further, nor did he inform the homeowner of the accident.A jury in the Superior Court for the judicial district of Waterbury found the defendant guilty of evasion of responsibility in the operation of a motor vehicle and tampering with physical evidence, based on the state’s theory that the defendant concealed the SUV to impair its availability in a criminal investigation. The Appellate Court affirmed the convictions, holding that a rational juror could find the act of concealment based on the context and circumstances, including the defendant’s flight from the scene and the temporary abandonment of the SUV in a private driveway.On further review, the Supreme Court of Connecticut concluded that the evidence was insufficient to establish concealment under General Statutes § 53a-155 (a). The court held that simply leaving the SUV in a visible spot at the front of a driveway, where its damage was apparent from the street, did not constitute concealment as required by the statute. The Supreme Court reversed the tampering conviction, directing the trial court to enter a judgment of acquittal on that charge and leaving resentencing, if any, to the trial court’s discretion. The remaining conviction was affirmed. View "State v. Bolden" on Justia Law