Justia Criminal Law Opinion Summaries

Douglas Eligha Taylor was originally convicted in 1995 for robbing four banks in Los Angeles, pleading guilty to multiple counts including armed bank robbery and using a firearm during a crime of violence. He was sentenced to 147 months in prison and a five-year term of supervised release. After his release in 2007, Taylor committed another bank robbery in 2008 and was prosecuted in state court, receiving a 17-year sentence. While in state custody, he was involved in a stabbing incident and accumulated multiple rules violations. Upon completing his state sentence in 2023, Taylor was transferred to federal custody, where the United States Probation Office petitioned to revoke his supervised release based on his 2008 conduct. Taylor admitted the allegations, and the district court accepted his admissions.The United States District Court for the Central District of California revoked Taylor’s supervised release and imposed a 60-month prison sentence, which was above the recommended Guidelines range of 18–24 months, followed by 24 months of supervised release. The court explained its decision by referencing Taylor’s repeated violations, the danger posed to the public, his lack of deterrence from prior sanctions, and the risk of recidivism. Taylor appealed, arguing that the district court committed procedural error by failing to adequately explain the sentence, improperly considering his prior criminal conduct, and imposing a substantively unreasonable sentence.The United States Court of Appeals for the Ninth Circuit reviewed the case and affirmed the district court’s decision. The appellate court held that the district court did not commit plain procedural error, adequately explained its reasons for the above-Guidelines sentence, and properly considered Taylor’s history and risk to the public. The court also found the sentence to be substantively reasonable and rejected Taylor’s arguments for a lower sentence. The judgment was affirmed. View "USA V. TAYLOR" on Justia Law

A U.K. citizen and former hedge fund manager predicted that the South African rand would strengthen against the U.S. dollar following a South African election. Acting on this belief, he purchased a one-touch barrier option for his hedge fund, which would pay $20 million if the rand-to-dollar exchange rate dropped below 12.50 before the option’s expiration. As the expiration approached and the rate hovered just above the threshold, he instructed a banker in Singapore to sell large amounts of dollars for rand to push the exchange rate below 12.50, thereby triggering the option and securing the payout for his fund. The trades were executed while he was in South Africa, and the payout obligations ultimately fell on U.S.-based financial institutions.A grand jury in the United States District Court for the Southern District of New York indicted him for commodities fraud and conspiracy to commit commodities fraud under the Commodity Exchange Act (CEA). At trial, the government presented evidence of his intent to manipulate the market to trigger the option. The jury convicted him of commodities fraud but acquitted him of conspiracy. The district court denied his post-trial motions for acquittal or a new trial, finding sufficient evidence of a direct and significant connection to U.S. commerce, adequate jury instructions, and no due process violation.On appeal, the United States Court of Appeals for the Second Circuit affirmed the conviction. The court held that the CEA’s extraterritoriality provision applied because the conduct had a direct and significant connection to U.S. commerce, given that U.S. financial institutions bore the payout risk. The court also found the jury instructions on intent and materiality were proper, that proof of an artificial price was not required under the charged anti-fraud provision, and that the defendant had fair notice his conduct was unlawful. The district court’s judgment was affirmed. View "United States v. Phillips" on Justia Law

The case concerns a defendant who was arrested and indicted for the murder of an individual named Donald Blake, with the allegation being that the murder was committed by blunt force trauma. At trial, the court instructed the jury on both murder and, over the defendant’s objection, the lesser-included offense of voluntary manslaughter. After more than five hours of deliberation, the jury returned a verdict of not guilty on murder and guilty on voluntary manslaughter. During jury polling, the eleventh juror indicated that the guilty verdict for manslaughter was not her true verdict, explaining she had been pressured by other jurors and maintained a not guilty stance. The trial judge, without instructing the jury to continue deliberations and over the objections of both parties, questioned the dissenting juror individually and then declared a mistrial.Following the mistrial, the State sought to retry the defendant for murder. The defendant moved for habeas corpus and for entry of a verdict of acquittal, arguing that jeopardy had attached to the murder charge because the jury had returned a final not guilty verdict. The Circuit Court denied relief, holding that jeopardy had not attached and that the State could retry the defendant for murder. The defendant’s appeal to the South Carolina Court of Appeals was dismissed as not immediately appealable, and his petitions for supersedeas and habeas corpus were denied. The Supreme Court of South Carolina then issued a common law writ of certiorari to review whether the State could retry the defendant for murder, and later requested briefing on the voluntary manslaughter charge as well.The Supreme Court of South Carolina held that jeopardy attached to both the murder and voluntary manslaughter charges. The Court found the not guilty verdict on murder was final and that the trial court’s sua sponte declaration of a mistrial, without manifest necessity and without instructing the jury to continue deliberations, barred retrial on both charges under double jeopardy principles. The Court reversed the lower court’s ruling, holding the State may not retry the defendant for either offense. View "The State v. Erb" on Justia Law

A man named Desoto rode his motorcycle to Kitchens’s auto shop, entered, and was shot by Kitchens after a brief, heated encounter. The incident was captured on surveillance video without audio. Testimony at trial described Desoto as a large, intimidating man who used threatening language toward Kitchens. Kitchens and his employees testified about Desoto’s size, appearance, and behavior, emphasizing that he was not a typical customer and that his actions were menacing. Kitchens claimed he acted out of sudden terror, fearing for his life due to Desoto’s threats and demeanor.After Kitchens was convicted of murder, the First Court of Appeals in Houston reversed and remanded for a new punishment trial, finding error in the trial court’s failure to submit a “sudden passion” instruction. At the new punishment trial, defense counsel continued to focus on Desoto’s intimidating appearance and alleged threats. During closing argument, the prosecutor suggested that Kitchens was prejudiced against Hispanics and that Desoto was perceived as “scary” because he was Hispanic. Defense counsel objected, arguing there was no evidence of racial motivation, but the trial court overruled the objection. The court of appeals later held that the prosecutor’s comments were a reasonable inference from the evidence and a permissible response to defense arguments.The Texas Court of Criminal Appeals reviewed the case and held that the prosecutor’s comments about Kitchens’s alleged prejudice against Hispanics were improper because there was no evidence in the record to support a finding of racial motivation. The court found that the prosecutor’s argument was not a reasonable deduction from the evidence nor a legitimate response to defense counsel. The judgment of the court of appeals was reversed, and the case was remanded for a harm analysis. View "KITCHENS v. STATE OF TEXAS" on Justia Law

The case concerns a defendant who was initially indicted for murder following the stabbing death of an individual in El Paso, Texas. The defendant was accused of killing the victim after a dispute during a sexual encounter, subsequently stealing the victim’s truck, and fleeing to Mexico. After his arrest, the defendant’s counsel repeatedly requested discovery and asserted readiness for trial, while the State delayed providing evidence and sought continuances, citing reasons such as incomplete forensic testing and missing witnesses.The 210th District Court of El Paso County first handled the case, where the defendant moved for dismissal on speedy trial grounds. In response, the State dismissed the murder indictment and reindicted the defendant for capital murder, announcing its intent to seek the death penalty. The defendant then moved to dismiss the new indictment, alleging prosecutorial vindictiveness—arguing that the State escalated the charges in retaliation for his assertion of speedy trial rights. The trial court found the State’s justifications not credible, determined that the reindictment was vindictive, and dismissed the case with prejudice. The State appealed, and the Eighth Court of Appeals affirmed, agreeing that the State acted vindictively and that dismissal with prejudice was warranted to neutralize the taint.The Texas Court of Criminal Appeals reviewed whether the trial court abused its discretion by dismissing the case with prejudice. The court held that, while the record supported a finding of prosecutorial vindictiveness, dismissal with prejudice was not necessary to neutralize the constitutional violation because the defendant’s speedy trial rights were not actually violated. The court concluded that the trial court exceeded its authority and modified the dismissal to be without prejudice, allowing the State to reindict the defendant for murder or a lesser-included offense at its discretion. The judgment of the Eighth Court of Appeals was reversed. View "STATE OF TEXAS v. GABALDON" on Justia Law

A woman who operated a daycare center for infants was charged with felony murder after a four-month-old child in her care died. Toxicology tests revealed a fatal level of diphenhydramine (an ingredient in Benadryl) in the infant’s blood. The prosecution’s theory was that the woman administered the drug to the child via a baby bottle, causing the child’s death. Evidence at trial included testimony from medical experts, daycare employees, and parents, as well as circumstantial evidence about the woman’s control over bottle preparation and the presence of diphenhydramine and related equipment in her home.After her initial conviction and a series of appeals, the Texas Seventh Court of Appeals ultimately affirmed her conviction following a retrial. The appellate court also upheld the trial court’s denial of her motion to suppress evidence obtained from electronic devices seized from her home and ruled that she had not preserved certain evidentiary objections for appeal because she failed to request a limiting instruction.The Texas Court of Criminal Appeals reviewed the case. It held that the evidence was legally sufficient to support the felony murder conviction, finding that a rational juror could conclude beyond a reasonable doubt that the woman administered a lethal dose of diphenhydramine to the infant, constituting an act clearly dangerous to human life. However, the court found that the search warrants for the electronic devices lacked a sufficient nexus between the alleged offense and the devices, making the search unconstitutional. The court also determined that the appellate court erred in its application of evidentiary rules regarding preservation of objections. The judgment was affirmed in part, reversed in part, and remanded for further proceedings. View "FRASER v. STATE OF TEXAS" on Justia Law

The case concerns a defendant who was arrested at a gas station mini-mart after officers, investigating an earlier robbery, observed him enter a single-occupancy restroom marked “Out of Order.” The defendant did not lock the door. Officers entered the restroom shortly after and found him standing on the handicap bars, reaching into the ceiling. A firearm was recovered from the ceiling area, and a subsequent search of the defendant revealed cash and various controlled substances. The government conceded that the officers lacked probable cause or reasonable suspicion to believe the defendant had committed a crime at the time they entered the restroom.The United States District Court for the Northern District of Illinois, Eastern Division, denied the defendant’s motion to suppress the evidence, finding he lacked a reasonable expectation of privacy in the out-of-order restroom. The court also found sufficient evidence to convict him of unlawful possession of a firearm by a felon and possession with intent to distribute a controlled substance following a bench trial. The defendant appealed, challenging the denial of the suppression motion, the sufficiency of the evidence for the firearm conviction, and sought to preserve a constitutional challenge to 18 U.S.C. § 922(g).The United States Court of Appeals for the Seventh Circuit affirmed the district court’s decision. The appellate court held that the defendant did not have a subjective or objectively reasonable expectation of privacy in the unlocked, out-of-order restroom, so the officers’ entry did not constitute a search under the Fourth Amendment. The court also found that sufficient evidence supported the conviction for unlawful possession of a firearm by a felon, based on constructive possession. Finally, the court held that the defendant waived his constitutional challenge to § 922(g) by failing to present any legal argument on appeal. View "United States v. Scott" on Justia Law

Miguel Salinas-Salcedo pled guilty to conspiracy to commit money laundering, admitting that over a two-and-a-half-year period he helped Mexican drug cartels launder nearly $3 million through 24 transactions. His role was to connect cartel members with individuals in the United States who could deposit and transfer large sums of cash into bank accounts without attracting government attention. Salinas-Salcedo acted as the intermediary, relaying instructions, authenticating transactions, and confirming deposits, ultimately earning over $44,000 in commissions. Unbeknownst to him, some of his contacts were undercover law enforcement agents.The United States District Court for the Northern District of Illinois, Eastern Division, sentenced Salinas-Salcedo after applying a four-level enhancement under U.S.S.G. §2S1.1(b)(2)(C) for being “in the business of laundering funds.” Salinas-Salcedo argued that he was merely a “middleman” and not in the business of laundering funds as contemplated by the guidelines. The district court rejected this argument, finding his participation integral to the conspiracy and imposing a below-guidelines sentence of 96 months.On appeal, the United States Court of Appeals for the Seventh Circuit reviewed the district court’s interpretation of the Sentencing Guidelines de novo, as the facts were undisputed. The appellate court held that Salinas-Salcedo’s conduct fell squarely within the scope of the “business of laundering funds” enhancement, as defined by the guidelines and relevant statutes. The court found that his regular, multi-year involvement, substantial earnings, and discussions with undercover agents satisfied the enhancement’s factors. The Seventh Circuit also rejected Salinas-Salcedo’s claim of procedural error, concluding that the district court adequately addressed his objections. The judgment was affirmed. View "United States v. Salinas-Salcedo" on Justia Law

Christopher Hill was charged with possession with intent to distribute methamphetamine after law enforcement, acting on information from a confidential informant, arranged a controlled purchase and arrested him en route to the meeting location. During the arrest, officers recovered approximately 100 grams of methamphetamine, a handgun, other drugs, and cash. Hill claimed the drugs were for personal use. He was indicted four days later and the case proceeded to a jury trial.During jury selection in the United States District Court for the Southern District of Indiana, two prospective jurors with family ties to law enforcement were questioned. Juror 53, who had been married to a sheriff’s officer and knew an officer involved in the case, expressed concerns about impartiality and was excused for cause. Juror 55, whose sons were in law enforcement, initially expressed concern about her ability to be impartial but ultimately stated she could judge the case based on the evidence and give equal weight to all testimony. The district court denied the motion to strike Juror 55 for cause, and she served on the jury. The jury found Hill guilty, and he was sentenced to 188 months in prison.On appeal, the United States Court of Appeals for the Seventh Circuit reviewed whether Hill’s right to an impartial jury was violated by the district court’s decision to seat Juror 55. Applying an abuse of discretion standard, the appellate court held that the district court did not err in crediting Juror 55’s assurances of impartiality, distinguishing her responses from those of Juror 53. The Seventh Circuit concluded that the trial judge acted within her discretion and affirmed Hill’s conviction. View "United States v. Hill" on Justia Law

A defendant was stopped by police in the early morning hours after being observed swerving and speeding. The officer detected signs of alcohol intoxication, and the defendant refused a chemical test, leading to a blood draw pursuant to a warrant. The defendant was charged with four misdemeanor offenses related to driving under the influence of alcohol and drugs, with additional allegations of a high blood alcohol content and refusal to submit to testing. The defendant, a military veteran, moved for pretrial military diversion under California Penal Code section 1001.80, submitting evidence of his military service and documentation of alcohol use disorder and other mental health conditions allegedly resulting from his service.The Superior Court of Orange County denied the motion for military diversion, reasoning that there was no nexus between the defendant’s alcohol abuse and his military service, and that his alcohol use predated his service. The court appeared to require the defendant to show a relationship between his qualifying condition and the commission of the charged offenses. The defendant then sought a writ of mandate from the California Court of Appeal, Fourth Appellate District, Division Three.The California Court of Appeal, Fourth Appellate District, Division Three, held that for misdemeanor charges, Penal Code section 1001.80 does not require a defendant to show a nexus between the qualifying condition (such as substance abuse) and the commission of the offense. The court further clarified that the burden of proof for eligibility is a “reasonable possibility” standard: the defendant must show a reasonable possibility that he is suffering from a qualifying condition as a result of military service. The court granted the writ, directed the trial court to vacate its denial, and ordered a new hearing applying the correct legal standards. View "Segura v. Superior Court" on Justia Law