Justia Criminal Law Opinion Summaries

Between 2019 and 2022, a bookkeeper for a family-owned machine and fabrication business misappropriated approximately $500,000 from her employer. She forged the co-owner’s signature on checks made out to herself and later confessed to the theft in a video-recorded interview with law enforcement. The bookkeeper admitted to taking funds for personal use and acknowledged the significant amount taken. She was charged with theft by unauthorized taking or transfer and forgery, pleaded not guilty, and proceeded to a jury trial.Prior to trial, the defendant sought access to the company’s QuickBooks password through a motion to compel discovery, which she later withdrew. She subsequently moved to suppress her confession as involuntary, but the Unified Criminal Docket (Piscataquis County, Roberts, J.) denied the motion after a hearing. Additional pretrial motions included a request for the trial judge’s recusal, based on his prior professional association with the prosecutor, and a motion to exclude financial evidence due to the State’s failure to produce the QuickBooks password. Both motions were denied. At trial, the prosecution presented testimonial, documentary, and video evidence, including the defendant’s confession. The jury found her guilty on both counts, and she was sentenced to concurrent prison terms, with part of the sentence suspended and probation imposed.On appeal, the Maine Supreme Judicial Court reviewed claims of prosecutorial error, denial of recusal, and alleged discovery violations. The Court held that although some prosecutorial statements constituted error, these were harmless in light of overwhelming evidence of guilt, including the defendant’s own confession. The Court also found no abuse of discretion in denying recusal or in rulings regarding discovery, concluding the State was not obligated to produce information it did not possess. The conviction was affirmed. View "State of Maine v. Moulton" on Justia Law

In this case, the defendant was convicted of bank robbery in Florida in 2024. His criminal history included a 2010 conviction in New York for attempted second-degree robbery, which involved forcibly stealing property from an elderly woman and causing her injury. After robbing the Florida bank, the defendant fled the state, led police on a high-speed chase in Virginia, and was eventually apprehended.The United States District Court for the Southern District of Florida accepted the defendant’s guilty plea for the bank robbery charge. During sentencing, the court calculated his sentence using the U.S. Sentencing Guidelines and applied a career offender enhancement based on two prior felony convictions for crimes of violence, one of which was his New York attempted robbery conviction. The defendant objected, arguing that attempted New York robbery did not qualify as a crime of violence under the Guidelines. The district court disagreed, relying on a recent amendment to the Guidelines that expressly included attempts to commit crimes of violence.On appeal, the United States Court of Appeals for the Eleventh Circuit reviewed the district court’s interpretation of the Sentencing Guidelines de novo. The Eleventh Circuit held that, following a 2023 amendment to the Guidelines, any attempt to commit a qualifying crime of violence is itself a crime of violence. The court confirmed that New York second-degree robbery qualifies as a crime of violence under the Guidelines’ elements clause. Therefore, the defendant’s attempt to commit that crime also qualifies. The Eleventh Circuit rejected the defendant’s arguments to the contrary and affirmed the sentence imposed by the district court. View "USA v. Ott" on Justia Law

During a law enforcement sting operation, the defendant sold fentanyl, methamphetamine, and drug paraphernalia near a church to a confidential informant. After the transaction, officers attempted to stop him, leading to a brief chase. The defendant was apprehended, and police recovered marked bills, various drugs, digital scales, and, along the route of the chase, a clear bag containing methamphetamine and a black bag containing a handgun and pills. Physical evidence and video footage of the transaction were introduced at trial. The pills were confirmed to contain fentanyl, and the cocaine found was packaged in a manner consistent with distribution.The Arkansas County Circuit Court jury convicted the defendant of multiple drug offenses, simultaneous possession of drugs and a firearm, and theft by receiving a firearm. He was sentenced to life plus an additional 185 years, with sentences to run consecutively, and a ten-year enhancement for drug crimes near a church. The defendant appealed, challenging the sufficiency of the evidence on all convictions and the sentence enhancement.The Supreme Court of Arkansas reviewed the evidence in the light most favorable to the verdict and found substantial evidence supporting all the drug-related convictions and the enhancement. The court held that circumstantial evidence sufficiently linked the defendant to the drugs and firearm found during the chase, allowing for the simultaneous possession conviction. However, the court determined there was not substantial evidence to support the theft-by-receiving conviction because the only proof the firearm was stolen was inadmissible hearsay testimony from an officer regarding a database entry. The Supreme Court of Arkansas affirmed all convictions except the theft-by-receiving conviction, which it reversed and remanded for entry of a new sentencing order. View "PARRIS v. STATE OF ARKANSAS" on Justia Law

The appellant was convicted by a jury of raping the 14-year-old daughter of his then-live-in girlfriend. The evidence included testimony that he sent the victim sexually explicit messages, gave her alcohol, and raped her while she was intoxicated. Several years later, after the appellant described to the victim’s mother in a series of electronic messages how he had raped his own daughters, the mother reported the abuse. Further testimony was provided by one of the appellant’s daughters, who described a longstanding pattern of sexual abuse and grooming by the appellant. The appellant was sentenced to life in prison.Prior to this appeal, the Garland County Circuit Court presided over the trial. The appellant moved for a continuance after being charged in a separate case with raping another of his daughters, arguing that the new charges impaired his ability to participate in his defense. The circuit court denied the motion, finding the appellant was able to assist his counsel. The court also overruled the appellant’s objections to the admission of explicit electronic messages and testimony from his daughter describing other uncharged sexual offenses, concluding that authentication and evidentiary standards were met. The jury convicted the appellant and imposed a life sentence.On review, the Supreme Court of Arkansas addressed the appellant’s challenges to both his conviction and sentence. The court held that substantial evidence supported the jury’s finding that the appellant was in a position of authority over the victim as required by Arkansas law. The court found no abuse of discretion in the denial of the continuance or in the admission of the challenged evidence, holding that the evidence was properly authenticated and the testimony of the appellant’s daughter was admissible under the “pedophile exception” to Arkansas Rule of Evidence 404(b). The court further held that the life sentence did not violate the Eighth Amendment or the Arkansas Constitution. The judgment was affirmed. View "FAULKNER V. STATE OF ARKANSAS" on Justia Law

A citizen of the Ivory Coast immigrated to the United States as a child refugee and later became a lawful permanent resident. As an adult, he was convicted in North Dakota of robbery, a Class B felony, for brandishing a gun and menacing others during a theft. The Department of Homeland Security initiated removal proceedings, charging him with removability based on two convictions for crimes involving moral turpitude and for the robbery conviction, which it classified as an aggravated felony for attempted theft.The Immigration Judge initially found the individual removable for the moral-turpitude convictions but determined he was eligible for cancellation of removal, concluding that the North Dakota robbery statute was overbroad compared to the federal definition of theft. The Department appealed, and the Board of Immigration Appeals (BIA) disagreed, finding the statute not facially overbroad and instructing the Immigration Judge to apply the “realistic probability” test to determine if the statute was applied to conduct beyond the generic federal definition. On remand, the Immigration Judge found the petitioner failed to show a realistic probability that the statute covered nongeneric conduct and ordered removal. The BIA dismissed the appeal, upholding the order.The United States Court of Appeals for the Eighth Circuit reviewed only the legal and constitutional claims, as required by statute. It held that North Dakota’s robbery statute is not unambiguously broader than the federal generic definition of attempted theft and that the petitioner had not demonstrated North Dakota actually prosecutes robbery based on conduct beyond that definition. Thus, the court found the robbery conviction to be an aggravated felony, rendering the petitioner ineligible for cancellation of removal, and denied the petition for review. View "Banyee v. Bondi" on Justia Law

In this case, the appellant and her son were charged in connection with an assault and shooting that took place in the stairwell of an apartment building in Southeast Washington, D.C. The incident followed a dispute earlier in the evening between the appellant and the victim, Shawn Watts. After being told to leave the apartment, the appellant returned with her son, who was armed. Together, they assaulted Mr. Watts, with the son ultimately shooting him in the leg. The appellant was tried separately from her son and faced several charges, including conspiracy to commit assault with a dangerous weapon, aggravated assault while armed, and possession of a firearm during a crime of violence (PFCV).The Superior Court of the District of Columbia presided over the jury trial. The jury convicted the appellant of conspiracy to commit assault with a dangerous weapon, aggravated assault while armed (including a “while armed” sentencing enhancement), and PFCV, but acquitted her on other counts. She was sentenced to seventy-two months of imprisonment, followed by supervised release. On appeal, she challenged the sufficiency of the evidence for the PFCV conviction and the “while armed” enhancement, and she also raised issues regarding the trial court’s handling of witness testimony and jury instructions.The District of Columbia Court of Appeals reviewed the case. The court concluded that there was insufficient evidence to sustain the appellant’s conviction for PFCV under an aiding-and-abetting theory, as there was no evidence that the victim posed a threat of disarming the gunman, or that the appellant’s actions were undertaken with the requisite guilty knowledge. However, the court found sufficient evidence for the “while armed” enhancement to the aggravated assault conviction, as the appellant knew about the gun and continued to participate in the assault. The court affirmed the convictions for conspiracy and aggravated assault with the enhancement, but reversed the PFCV conviction. View "Chandler v. United States" on Justia Law

A Black man was charged with two counts of first-degree sexual abuse and one count of attempted robbery after allegedly assaulting a white woman. During jury selection, the government used its peremptory strikes to remove all six nonwhite prospective jurors—four Black, one Asian, and one Hispanic—from a venire of thirty-six, resulting in an all-white jury. The defense objected, arguing that the prosecutor’s actions were racially discriminatory and violated the precedent established in Batson v. Kentucky. The government provided purportedly race-neutral reasons for the strikes of the Black jurors, such as concerns about their ability to understand scientific testimony or responses during voir dire. The trial court accepted these explanations, found them credible and race-neutral, and denied the Batson challenge.A jury in the Superior Court of the District of Columbia acquitted the defendant of attempted robbery but convicted him on both sexual abuse counts. On appeal, a division of the District of Columbia Court of Appeals affirmed the convictions, concluding that the trial court had adequately scrutinized the government’s justifications for the jury strikes. The defendant sought en banc review, and the division’s decision was vacated pending review by the full District of Columbia Court of Appeals.The District of Columbia Court of Appeals, sitting en banc, held that the trial court’s Batson analysis was insufficient because it failed to rigorously scrutinize the prosecutor’s explanations in the context of the entire record, including statistical evidence and the racially charged nature of the case. The court found that at least one of the government’s strikes was more likely than not racially discriminatory. Accordingly, it reversed the defendant’s convictions and remanded for a new trial. View "Smith v. United States" on Justia Law

The defendant was charged with practicing law without a license after submitting court filings on behalf of another individual in a criminal case in Wells County, North Dakota. The filings included motions and related documents, each signed to indicate the defendant was representing the incarcerated individual. The State filed charges based on these actions, and after pretrial proceedings, the case proceeded to a jury trial.Prior to trial, the District Court of Wells County addressed several motions. The defendant’s motion to dismiss, based on alleged unlawful access by law enforcement to jail communications, was denied as untimely under the court’s pretrial order and applicable procedural rules. The State’s motion to amend the information to expand the offense date was granted after the court found no additional or different offense was charged and no substantial right was prejudiced. The court also ruled, over the defendant’s objection, that the offense of practicing law without a license was a strict liability crime under North Dakota law, and removed the requirement of a culpable mental state from the jury instructions. The jury returned a guilty verdict, and the district court entered a criminal judgment and sentenced the defendant.On appeal to the Supreme Court of North Dakota, the defendant raised several issues. The court only considered those claims that were properly preserved and sufficiently briefed. The Supreme Court found the district court did not abuse its discretion in denying the motion to dismiss as untimely, allowing amendment of the information, or removing the mens rea element from the jury instructions. The Supreme Court held that the statute under which the defendant was convicted is a strict liability offense, and the jury instructions accurately reflected the law. The criminal judgment was affirmed. View "State v. Olson" on Justia Law

Law enforcement discovered a handgun in a vehicle parked outside a bar while the defendant was inside the bar. The defendant, who was previously convicted of a qualifying offense, was charged with unlawful possession of a firearm by a felon. At trial, the defendant objected to the proposed jury instructions regarding the definition of “possession,” arguing that the instructions failed to require proof of intent as allegedly mandated by recent amendments to the relevant statute. The defendant also moved for a judgment of acquittal, asserting insufficient evidence linked him to the vehicle containing the gun. The court denied the motion, and the jury returned a guilty verdict.The District Court of Ward County presided over the trial. The defendant’s objections to the jury instructions were overruled, and the motion for judgment of acquittal was denied. After conviction, the defendant appealed, arguing that the district court erred in its jury instructions by not requiring the State to prove intent to possess the firearm and by not entering a judgment of acquittal due to insufficient evidence that the handgun qualified as a “firearm” under the law.The Supreme Court of North Dakota reviewed the case and held that, under the amended statute, intent is required only for convictions based on constructive possession, not for actual possession, and the district court’s jury instructions properly reflected this distinction. The Court also held that there was sufficient circumstantial evidence for a rational fact finder to conclude the handgun was functional, as required by statute, and thus the district court did not commit obvious error by failing to enter a judgment of acquittal. The Supreme Court of North Dakota affirmed the criminal judgment. View "State v. Luetzen" on Justia Law

Authorities responded to a residence to investigate an alleged assault involving a young child. Upon arrival, social workers and a detective entered the property through an open garage door, which led to an interior entryway. The resident, Shantel Lais, allowed them inside. Once inside, the detective observed hazardous conditions, including accessible firearms, open alcohol, drugs, and drug paraphernalia within reach of a two-year-old child. As a result, Christopher Golberg was charged with child neglect, unlawful possession of drug paraphernalia, and unlawful possession of a firearm.Prior to trial in the District Court of Mercer County, South Central Judicial District, Golberg moved to suppress evidence obtained during the search, arguing the detective unlawfully entered the garage without a warrant or consent, thus tainting the evidence subsequently gathered. A suppression hearing was held, where the detective testified that the garage functioned as the main entrance due to home construction and that the exterior door was open. The district court found that Golberg did not have a reasonable expectation of privacy in the garage under these circumstances and denied the motion to suppress. At trial, Golberg twice moved for judgment of acquittal on the basis that he did not reside at the house; both motions were denied. The jury found Golberg guilty of child neglect and not guilty on the other charges.On appeal, the Supreme Court of North Dakota considered whether the denial of the suppression motion and the sufficiency of the evidence were erroneous. The court held that the open garage, serving as the main access point and lacking express signs restricting entry, did not afford Golberg a reasonable expectation of privacy. Thus, no unlawful search occurred. The court also found that sufficient evidence supported the jury’s verdict on child neglect. The amended criminal judgment was affirmed. View "State v. Golberg" on Justia Law