Justia Criminal Law Opinion Summaries

The case involved a defendant who was convicted by a jury of first-degree murder and two counts of attempted murder, all arising from a gang-related shooting in Visalia, California. The prosecution presented evidence that the defendant was a member of the North Side Visalia gang and that he shot individuals he believed to be rival gang members, resulting in one death and serious injury to another. The prosecution’s case relied heavily on expert testimony to establish the defendant’s gang membership and the gang-related nature of the crimes, as well as evidence of prior offenses by the defendant and other gang members. The defense argued that the shooting was not premeditated or gang-motivated, but rather stemmed from a personal dispute, and presented evidence that the defendant had renounced gang affiliation.The Tulare County Superior Court denied the defendant’s pretrial motion to recuse the entire District Attorney’s Office after his former defense attorney joined that office, finding that an effective ethical wall had been established. At trial, the jury found the defendant guilty on all counts, found true the gang enhancements and the gang-murder special circumstance, and returned a death verdict. The trial court entered judgment accordingly.On automatic appeal, the Supreme Court of California reviewed the case. The court held that, due to subsequent legal developments—specifically, its decision in People v. Sanchez and legislative amendments to Penal Code section 186.22 by Assembly Bill 333—the evidence was insufficient to support the gang enhancements and the gang-murder special circumstance. As a result, the court reversed the gang-related findings and the death judgment. The court also ordered a limited remand to allow the defendant to further develop his claim that his trial counsel violated his Sixth Amendment right of autonomy over the defense, as articulated in McCoy v. Louisiana. The convictions and death judgment were reversed and the case remanded for further proceedings. View "P. v. Cardenas" on Justia Law

The case concerns a woman who was convicted and sentenced to death in 1993 for the murders of her husband and two children, whom she killed by setting their apartment on fire while they slept. Investigators found evidence of premeditation, including the use of accelerants, disabled smoke detectors, and severed power to the apartment. The defendant was the beneficiary of several life insurance policies on the victims. After her conviction, she pursued multiple avenues of post-conviction relief in both state and federal courts over the next three decades, raising various claims, including ineffective assistance of counsel.After her initial conviction and sentencing in Ada County, the defendant filed her first post-conviction petition, which was denied by the district court. The Idaho Supreme Court affirmed, finding that her trial counsel had conducted reasonable investigation and that she failed to show prejudice. In subsequent years, she filed several more post-conviction petitions in state court and two federal habeas corpus actions, all of which were unsuccessful. Notably, her claim that trial counsel failed to investigate and present evidence of her alleged brain damage was not raised until her second post-conviction petition, which the Idaho Supreme Court found to be untimely under Idaho Code section 19-2719, as the claim could have been raised earlier.The Supreme Court of the State of Idaho reviewed her sixth post-conviction petition, in which she again argued ineffective assistance of trial and post-conviction counsel, and contended that recent federal case law (Shinn v. Ramirez) should allow her to relitigate her claims. The Idaho Supreme Court held that Idaho Code section 19-2719 strictly limits post-conviction claims to those raised within forty-two days of the death sentence, unless the claims were not and could not reasonably have been known. The court concluded that neither changes in federal law nor alleged ineffective assistance of post-conviction counsel excused her untimely filing, and affirmed the district court’s summary dismissal of her petition as time-barred. View "Row v. State" on Justia Law

Two young sisters reported to their mother that their father had sexually abused them. The mother contacted the police, and after an investigation, the State charged the father with multiple offenses related to the sexual abuse of both daughters, who were under the age of twelve at the time. Before trial, the defense sought permission to introduce evidence of the daughters’ prior sexual abuse allegations against other individuals, including a half-brother and a cousin, arguing this evidence was relevant to their credibility and knowledge of sexual matters. The defense also requested to admit a police report describing the children’s inappropriate behavior, but later withdrew some of these requests.The Superior Court of the State of Delaware denied the defense’s motion to admit the prior allegations, finding the evidence either nonspecific or lacking proof of falsity, and applied a clear and convincing evidence standard for showing that prior allegations were false. At trial, both daughters testified, with one allowed to hold a stuffed animal for comfort. The jury convicted the father on most charges, and he was sentenced to 119 years in prison. The defense moved for a new trial, arguing the court used the wrong legal standard for admitting the prior allegations and improperly allowed the comfort item. The Superior Court denied the motion, reaffirming its evidentiary rulings and the standard applied.On appeal, the Supreme Court of the State of Delaware reviewed whether the Superior Court applied the correct legal standard regarding the admissibility of prior sexual abuse allegations and whether it abused its discretion in allowing the comfort item. The Supreme Court held that, regardless of the standard, the defense failed to present any evidence that the prior allegations were false, and thus exclusion was proper. The Court also found no abuse of discretion in permitting the child to hold a stuffed animal while testifying. The convictions and judgment were affirmed. View "Massey v. State" on Justia Law

A man was convicted by a jury of sexually abusing his ten-year-old stepgranddaughter on two occasions in 2022. The abuse included inappropriate touching and digital penetration, occurring once in May and again in late August at the child’s home while he was babysitting. The child disclosed the abuse to her mother several weeks later, which led to a police investigation. During the investigation, the man denied the allegations and agreed to take a polygraph examination, which indicated no deception regarding whether he had touched the child’s vagina or buttocks on a specific Sunday in August. However, the abuse was alleged to have occurred on a Saturday and in May.The District Court of Campbell County presided over the trial. At trial, the State moved to exclude any reference to the polygraph examination, arguing it was inadmissible under Wyoming Rules of Evidence 702 and 403. The court granted the motion, and the jury found the defendant guilty on all counts. He was sentenced to consecutive prison terms. While his direct appeal was pending, the defendant filed a motion for a new trial under Wyoming Rule of Appellate Procedure 21, claiming ineffective assistance of counsel for failing to request a Daubert hearing on the admissibility of the polygraph results. After an evidentiary hearing, the district court denied the motion, finding no prejudice because the polygraph evidence would not have been admissible.The Supreme Court of Wyoming reviewed the consolidated appeals, focusing solely on the denial of the Rule 21 motion. The court held that the defendant failed to show prejudice, as the polygraph results would not have satisfied the requirements for admissibility under Daubert and Rule 702, nor would they have assisted the jury or fit the facts of the case. The court affirmed the district court’s denial of the motion for a new trial. View "Morris v. The State of Wyoming" on Justia Law

In this case, the appellant was convicted in 2010 of several offenses, including aggravated assault while armed, after shooting an individual who was set to testify against his brother. The victim suffered serious injuries. The appellant was sentenced to a total of 336 months in prison, a sentence that was below the statutory maximum for the most serious offense. After an initial appeal, the District of Columbia Court of Appeals affirmed the convictions but remanded for merger of certain offenses and resentencing. The trial court resentenced the appellant to the same term, and the Court of Appeals again affirmed, rejecting arguments that the sentence was improperly enhanced based on prior convictions.Subsequently, the appellant succeeded in having one of his prior convictions vacated. He then moved for resentencing in the Superior Court of the District of Columbia, arguing that his sentence had been enhanced based on the now-vacated conviction and that his two remaining prior convictions should not have counted separately for enhancement purposes. The trial court granted resentencing, but determined that the two remaining convictions qualified as separate prior felonies under the relevant statute and resentenced the appellant to 240 months, again below the statutory maximum but above the advisory range in the Voluntary Sentencing Guidelines.On appeal, the District of Columbia Court of Appeals reviewed whether the trial court erred in applying the sentencing enhancement statute when the two prior convictions were adjudicated together. The court declined to reach the substantive statutory interpretation question, holding that because the sentence imposed was below the statutory maximum, it was not reviewable on the grounds asserted. The court reaffirmed that discretionary sentencing within statutory limits, even if based on an alleged misapplication of the Guidelines or enhancement statutes, is not subject to appellate review unless it involves materially false factual information. The judgment of the trial court was affirmed. View "Johnson v. United States" on Justia Law

A man was convicted by a jury of several offenses related to a shooting outside a nightclub in Washington, D.C. in July 2021. The evidence showed that the defendant, who was twenty years old at the time, shot another individual and then hid the firearm. He was identified by a witness, and DNA evidence linked him to the recovered handgun. The defendant initially told police he was not the shooter, but at trial, he admitted to firing the gun, claiming self-defense.Prior to trial in the Superior Court of the District of Columbia, the defendant moved to dismiss charges related to carrying a pistol without a license, possession of an unregistered firearm, and unlawful possession of ammunition. He argued that the District’s laws, which require individuals to be at least twenty-one years old to obtain a firearm registration or license, violated the Second Amendment, especially in light of the Supreme Court’s decision in New York State Rifle & Pistol Association, Inc. v. Bruen. The trial court denied the motion, finding the age-based restrictions consistent with the Second Amendment and historical firearm regulation. At trial, the government impeached the defendant’s credibility by highlighting inconsistencies between his initial statements and his trial testimony. The jury convicted him on all counts.On appeal, the District of Columbia Court of Appeals reviewed the constitutionality of the District’s age-based firearm registration and licensing statutes and the propriety of the government’s arguments regarding the defendant’s credibility. The court held that the age-based statutes are constitutional because they are consistent with the nation’s historical tradition of firearm regulation. The court also found that the government’s arguments about the defendant’s change in defense theory were not improper. The court affirmed the convictions but remanded for the limited purpose of merging certain convictions and resentencing as necessary. View "Picon v. United States" on Justia Law

In this case, the appellant was convicted of simple assault with a bias enhancement after an incident at a Metro station. The government’s evidence showed that the appellant approached a group, made derogatory remarks about their sexual orientation, and physically assaulted one of them multiple times. The assailant was later apprehended at a different Metro station and identified as the appellant. The charges were eventually narrowed to simple assault with a bias enhancement, and the appellant was found guilty by a jury.Prior to trial in the Superior Court of the District of Columbia, the appellant objected to the composition of the jury venire, arguing that it did not reflect a fair cross-section of the community, as only three of fifty-four potential jurors appeared to be African American. The trial judge denied the motion to strike the panel, finding that the appellant had not shown systematic exclusion of a group from the jury selection process. The judge also denied a subsequent, untimely request for access to jury selection records, reasoning that the request came only after the motion to strike had been denied and that no prior efforts had been made to obtain such records.On appeal, the District of Columbia Court of Appeals reviewed the sufficiency of the evidence and the fair cross-section claim. The court held that there was sufficient evidence for a reasonable juror to find the appellant guilty beyond a reasonable doubt, based on the testimony of the arresting officer and the circumstances of the arrest. The court also held that the trial court did not err in denying the motion to strike the jury panel or the belated request for jury selection records, finding that the denial was based on the untimeliness of the request rather than an improper threshold requirement. The judgment of the Superior Court was affirmed. View "Brown v. United States" on Justia Law

The appellant was represented by an attorney in a criminal contempt proceeding after allegedly violating a civil protective order. During the course of representation, the appellant twice made statements to his attorney threatening to kill the Assistant Attorney General prosecuting his case, including specific language and gestures indicating an intent to cause harm. The attorney, disturbed by these threats, initially sought to withdraw from representation and later disclosed the threats to the court after being ordered to do so. The attorney subsequently testified before a grand jury and at trial regarding the threats, which led to the appellant being charged and convicted by a jury of threatening a public official and obstruction of justice.Following conviction in the Superior Court of the District of Columbia, the appellant challenged the admissibility of his attorney’s testimony, arguing that the statements were protected by the attorney-client privilege. The trial court rejected this argument, finding that the threats were not made for the purpose of seeking legal advice and thus were not privileged. On appeal, a division of the District of Columbia Court of Appeals initially vacated the convictions, holding that the statements were privileged and their admission was not harmless error. The United States successfully petitioned for en banc review, and the full court vacated the division’s decision, limiting the scope of review to the attorney-client privilege issue.The District of Columbia Court of Appeals, sitting en banc, held that the attorney-client privilege does not protect communications that themselves constitute criminal threats to cause death or serious bodily harm. The court reasoned that such threats are an abuse of the attorney-client relationship and fall outside the privilege, regardless of whether the technical elements of the privilege are otherwise met. The court affirmed the Superior Court’s admission of the attorney’s testimony and remanded the case for consideration of the appellant’s remaining arguments. View "Moore v. United States" on Justia Law

A woman returning home late at night observed a man, later identified as the defendant, standing near the entrance of their shared condominium building with his lower body exposed. The man, wearing a sweatshirt that did not cover his genitalia, followed the woman as she entered the building, attempted to force his way inside, and did not try to cover himself. After a confrontation inside the building, the woman took what she believed to be the man’s phone and exited to call the police. The man followed her outside, continued to expose himself, and engaged in a physical altercation with her.The Superior Court of the District of Columbia initially convicted the defendant of lewd, indecent, or obscene acts in violation of D.C. Code § 22-1312 after a bench trial. The conviction was vacated following a post-conviction motion for ineffective assistance of counsel, and a new trial was scheduled. The government’s request to continue the trial, due to the unavailability of the key witness, was granted over the defendant’s objection. At the second trial, the court again found the defendant guilty, concluding that his exposure on the walkway in front of the building—an area open to public view—constituted a violation of the statute.On appeal, the District of Columbia Court of Appeals held that D.C. Code § 22-1312 is not limited to conduct occurring on public property; rather, it applies to indecent exposures in any location “in public,” meaning in open view or before the public at large, regardless of property ownership. The court also determined that any error in granting the government’s motion to continue the trial was harmless, as the defendant failed to show prejudice. The conviction was affirmed. View "Flowers v. District of Columbia" on Justia Law

Police received reports of a group committing robberies or attempted robberies in a white Nissan Rogue that had been reported stolen. Officers tracked the vehicle, observed it being driven recklessly, and saw it crash. Four individuals, including E.A., fled from the car. E.A. was apprehended shortly after the crash, frisked, and found to have a handgun in his sweatshirt pocket. He was subsequently charged with carrying a pistol without a license and possession of an unregistered firearm.The Superior Court of the District of Columbia denied E.A.’s motion to suppress the handgun, finding that officers had reasonable articulable suspicion to stop and frisk him based on his association with the group suspected of recent robberies and the stolen vehicle, as well as his flight from the crash. The court also concluded that, even if the officers’ actions exceeded the scope of a Terry stop, they had probable cause to arrest E.A. for multiple offenses, justifying a search incident to arrest. E.A. was adjudicated delinquent on both firearms charges and appealed, challenging the denial of his suppression motion.The District of Columbia Court of Appeals reviewed the case and affirmed the Superior Court’s judgment. The appellate court held that the officers had reasonable articulable suspicion to stop and frisk E.A., relying on the collective knowledge from radio dispatches, corroborated by officers’ observations and the circumstances of the stop. The court further held that the officers’ use of handcuffs and drawn weapons did not convert the stop into an arrest, given the safety concerns and flight risk. Therefore, the search and seizure of the handgun did not violate the Fourth Amendment, and the judgment was affirmed. View "In re E.A." on Justia Law