Justia Criminal Law Opinion Summaries

The case concerns the shooting death of Mikfeesha Dotson on October 24, 2020, in a motel room in Stone Mountain, Georgia. Faruk Adedapo Fadesire was present in the room with Bianca Walker when Dotson arrived. After Dotson entered, Walker heard gunshots while her back was turned and found Dotson shot when she turned back around. Fadesire immediately left the room. Police found Fadesire’s identification and a debit card in the room, along with three spent 9-millimeter cartridge casings. The room was registered to Fadesire. Walker later identified Fadesire in a photo lineup. Several weeks later, police arrested Fadesire and found a 9-millimeter pistol at the location of his arrest; ballistic evidence linked the gun to the casings found at the scene.Fadesire was indicted in the Superior Court of DeKalb County for malice murder, felony murder, aggravated assault, and possession of a firearm during the commission of a felony. A jury found him guilty on all counts. The trial court sentenced him to life imprisonment for malice murder and additional time for the firearm offense. Fadesire moved for a new trial, arguing ineffective assistance of counsel due to his lawyer’s failure to object to certain remarks by the prosecutor during closing argument. The trial court denied this motion, and Fadesire appealed.The Supreme Court of Georgia reviewed the case. The court held that Fadesire’s counsel was not constitutionally ineffective for not objecting to the prosecutor’s remarks during closing argument. The court found that the remarks were not obviously improper, and that a reasonable lawyer could have chosen not to object as a strategic matter. Accordingly, the Supreme Court of Georgia affirmed Fadesire’s convictions. View "FADESIRE v. THE STATE" on Justia Law

Alexandra Bodie was convicted of malice murder and possession of a firearm during the commission of a felony, arising from the fatal shooting of Brandy Brummett in a parking lot in May 2019. Surveillance footage and eyewitness testimony identified Bodie as the shooter. Bodie initially denied involvement but later admitted in a police interview that she was present and that the gun discharged during a confrontation, claiming she did not intend to shoot Brummett and suggesting the gun fired accidentally during a struggle. Evidence at trial showed a history of conflict between Bodie and Brummett over drug territory, and additional testimony and social media posts indicated underlying tension and potential motive.The Superior Court of DeKalb County conducted a jury trial in July 2022. The jury found Bodie guilty on all counts. The court sentenced her to life imprisonment for malice murder and a consecutive five-year term for the firearm offense. After her conviction, Bodie, with new counsel, moved for a new trial, arguing ineffective assistance of her trial counsel and plain error by the trial court for not instructing the jury on accident. The trial court denied her motion following an evidentiary hearing in July 2025, and Bodie appealed.The Supreme Court of Georgia reviewed the case on appeal. The Court held that Bodie did not demonstrate her trial counsel’s performance was deficient for failing to request an accident instruction, as focusing on self-defense rather than accident was a reasonable strategic decision. The Court further determined that, even if the trial court erred in not instructing on accident, Bodie failed to show this omission affected the trial’s outcome. The Court also rejected her claim of cumulative error, finding no errors to aggregate. The Supreme Court of Georgia affirmed Bodie’s convictions. View "BODIE v. THE STATE" on Justia Law

The case concerns Carlos Dill, who was convicted of malice murder and related offenses following the shooting death of Jonathan Stafford. Key evidence showed that Dill had a controlling and abusive relationship with Tatiana Willis-Riley, ending with numerous calls and texts expressing anger and perceived disrespect after Willis-Riley spent Thanksgiving with Stafford. Surveillance footage and witness testimony established that Dill lay in wait at Willis-Riley’s apartment complex, ambushed Stafford, shot him multiple times, took a gun from the scene, and fled. Dill was apprehended at a hospital with a gunshot wound. His defense at trial was that the killing constituted voluntary manslaughter due to provocation.Following a jury trial in the Superior Court of Fulton County, Dill was convicted on all counts, including malice murder, and sentenced as a recidivist to consecutive life sentences without parole. He moved for a new trial, arguing insufficient evidence for malice murder, juror misconduct, and ineffective assistance of counsel. After hearings, the trial court denied his motion.On appeal, the Supreme Court of Georgia reviewed whether the evidence was sufficient to support the malice murder conviction, whether the trial court abused its discretion in failing to remove a juror who interacted with the victim’s companion, and whether Dill’s counsel was constitutionally ineffective. The court held that the evidence was constitutionally sufficient for malice murder, the juror’s contact was inconsequential and did not prejudice Dill, and trial counsel’s performance did not amount to ineffective assistance, as Dill could not demonstrate prejudice or deficient performance. The Supreme Court of Georgia affirmed the trial court’s judgment and Dill’s convictions. View "DILL v. THE STATE" on Justia Law

The case concerns Michael Eric Simms, who was convicted by a Fulton County jury of felony murder and other related charges following the shooting death of Seadee Karram Jones in July 2015. During jury selection, one of the jurors, identified as F.S., indicated he was originally from Mexico but was not asked about his citizenship status during voir dire. After the trial, Simms’s counsel learned from another attorney that F.S. was not a U.S. citizen, a fact F.S. had disclosed on his jury questionnaire and confirmed at a later hearing. F.S. had nonetheless been told by the court’s jury-services division that he was required to appear for jury service.After the convictions, Simms, through various counsel, filed a motion for a new trial in the Superior Court of Fulton County, raising, among other issues, the participation of a non-citizen juror. The trial court denied the motion, concluding that Simms had not preserved this claim because he did not object to F.S.’s participation at trial.The Supreme Court of Georgia reviewed the case and determined that the trial court had applied the wrong legal standard in assessing waiver of the non-citizen juror claim. The Supreme Court clarified that, under Georgia law, failing to object to an ineligible juror does not waive the issue unless the party knew or could have discovered the juror’s ineligibility through the timely exercise of ordinary diligence. Since the trial court did not address whether Simms or his counsel knew or could have discovered F.S.’s ineligibility, the Supreme Court vacated the judgment and remanded the case for further proceedings. The trial court was instructed to determine, using the correct standard, whether Simms had waived his claim and, if not, to address the merits of the claim. View "SIMMS v. THE STATE" on Justia Law

The case concerns Gustavo Hernandez, who was convicted for malice murder and related offenses following the fatal shooting of Daniel Perez in March 2018. Evidence at trial showed that Hernandez, along with several co-defendants, planned to rob Perez under the pretense of a marijuana sale. Perez was shot in the head while sitting in his brother’s truck and died three days later. Testimony from co-defendants, who entered plea deals, indicated that Hernandez admitted to the shooting immediately after the incident. Forensic evidence and the recovery of ammunition further linked Hernandez to the crime.After being tried by a jury in the Superior Court of Cobb County, Hernandez was found guilty on all counts. The court sentenced him to life imprisonment for malice murder, with additional consecutive sentences for conspiracy to commit armed robbery and possession of a firearm during the commission of a felony. The other felony murder charges were vacated by operation of law, and certain counts merged into others. Hernandez initially filed a motion for a new trial, which was later amended to include claims of ineffective assistance of counsel based on his trial attorney’s failure to object to certain statements during the prosecutor’s closing argument. The trial court denied this motion following a hearing.The Supreme Court of Georgia reviewed Hernandez’s appeal, specifically his claims of ineffective assistance. The court held that none of the prosecutor’s closing arguments identified by Hernandez constituted improper statements that would have warranted an objection. The court found that trial counsel’s decisions not to object were not objectively unreasonable and did not amount to deficient performance under the standard set in Strickland v. Washington. Because there was no deficient performance, the court also rejected Hernandez’s claim of cumulative prejudice. The Supreme Court of Georgia affirmed Hernandez’s convictions and sentences. View "HERNANDEZ v. THE STATE" on Justia Law

The case concerns Maurice Badie’s convictions for malice murder and related offenses stemming from a fatal public gunfight on July 17, 2008. Evidence presented at trial showed that earlier that day, the victim, Christopher Ramsay, threatened a young man named R.B. at gunpoint. Later, after this incident was relayed to others, Ramsay was confronted by a group and warned of consequences. That night, multiple gunmen, including Badie, ambushed Ramsay and his companions, firing numerous shots. Ramsay was killed and four others were wounded. Three eyewitnesses placed Badie at the scene; two saw him armed, and one saw him shoot toward the victims.A Fulton County grand jury indicted Badie, Domonique Hodo, and Matthew Benton on multiple counts. The State dismissed the charges against Hodo before trial. Badie and Benton were tried jointly and convicted on all counts by a jury in the Superior Court of Fulton County. Badie received a sentence of life imprisonment and additional consecutive terms. Benton’s convictions were later reversed by the Supreme Court of Georgia due to issues with his custodial statement, and he subsequently pled guilty to a lesser offense. Badie’s motions for a new trial were denied by the trial court after hearings and amendments over several years.The Supreme Court of Georgia reviewed Badie’s appeal. The Court held that the evidence was constitutionally sufficient to support Badie’s convictions. It rejected Badie’s argument for a new trial based on Benton’s subsequent plea, finding that Badie was not charged solely as an accessory. The Court found no Confrontation Clause violation under Bruton v. United States, and determined that the lack of a limiting instruction was not plain error given the strength of other evidence. Badie’s claims of ineffective assistance of counsel and his challenge to the trial court’s refusal to grant a new trial were also denied. The judgment was affirmed. View "BADIE v. THE STATE" on Justia Law

The case concerns a defendant who was convicted for malice murder and other related offenses following the shooting death of an individual during a gathering at an apartment. The evidence at trial showed that the defendant arrived at the gathering, consumed significant amounts of alcohol, and became involved in a confrontation where he brandished a firearm. Despite being urged to put the gun away, he fired at the victim, causing fatal injuries, and then attempted to shoot himself. Law enforcement responded to the scene, and the defendant was later interviewed by police but did not claim self-defense.A Cobb County grand jury indicted the defendant on multiple counts, including malice murder, felony murder, aggravated assault, and firearm-related charges. At trial, the jury found him guilty on all counts. The Superior Court of Cobb County sentenced him to life without parole plus additional probation terms. The trial court vacated some counts by operation of law and merged others for sentencing. After his conviction, the defendant filed a motion for a new trial, which was denied following an evidentiary hearing.Upon appeal, the Supreme Court of Georgia reviewed the defendant’s argument that his due process rights were violated during sentencing. He contended that the trial judge’s statements about the risks of apologizing (which could affect his appeal) and consideration of his lack of remorse rendered his sentence unconstitutional. The Supreme Court of Georgia held that the trial court did not rely on improper considerations; it properly considered the defendant’s conduct and lack of remorse as evidenced during trial and police interview, not his silence at sentencing. The Court found no due process violation and affirmed the judgment. View "BUSTAMENTE v. THE STATE" on Justia Law

In this case, a witness in Laredo, Texas, reported hearing multiple gunshots fired from a black Cadillac SUV with a missing right rear taillight. Police responded, gathered shell casings, and located a gray Cadillac SRX matching the description, which had been previously stopped by police several days earlier with Jesus Eloy Garcia as one of the passengers. Based on the witness’s account, investigative findings, and past police encounters, law enforcement issued a “be-on-the-lookout” (BOLO) alert identifying the vehicle, its distinguishing features, and possible occupants. Later that day, officers located the Cadillac with three occupants, including Garcia, and conducted an investigatory stop. During the stop, Garcia was questioned, and bodycam footage was recorded.The United States District Court for the Southern District of Texas denied Garcia’s motion to suppress the bodycam evidence, ruling that the investigatory stop was supported by reasonable suspicion. Garcia subsequently pleaded guilty to being a felon in possession of a firearm but reserved his right to appeal the denial of the suppression motion. He argued on appeal that the stop was not supported by reasonable suspicion and that the BOLO lacked the necessary specificity, so the evidence derived from the stop should be excluded.The United States Court of Appeals for the Fifth Circuit reviewed the district court’s factual findings for clear error and its legal conclusions de novo. The Fifth Circuit held that the investigatory stop was supported by reasonable suspicion under the totality of the circumstances. The court found that the BOLO contained sufficient detail, was based on multiple sources, and provided an adequate basis for the stop. The court affirmed the district court’s judgment, rejecting Garcia’s arguments and upholding the denial of the motion to suppress. View "United States v. Garcia" on Justia Law

The defendant pled guilty to illegally reentering the United States after a felony conviction. His Presentence Investigation Report (PSR) recommended two discretionary conditions of supervised release: that he report to Immigration and Customs Enforcement (ICE) upon release and, if allowed to return to the United States, report to probation within 72 hours, and that he seek proper work authorization from ICE before working. Neither the defendant nor the government objected to these conditions before or during sentencing.The United States District Court for the Southern District of Texas conducted the sentencing. At the hearing, the court confirmed that both parties had reviewed the PSR and that no objections had been filed. The court specifically asked defense counsel if she had reviewed with the defendant the fact that no objections were made, and counsel confirmed this. The court then orally adopted the PSR and its appendix, which included the supervised-release conditions, and imposed the sentence. The written judgment reflected these conditions.The United States Court of Appeals for the Fifth Circuit reviewed the case. The defendant argued that the district court failed to adequately pronounce the conditions and did not properly verify, as required by United States v. Diggles and Federal Rule of Criminal Procedure 32(i)(1)(A), that he had reviewed the PSR with counsel. The appellate court found that the district court’s oral adoption of the PSR satisfied Diggles and that the record showed the defendant had ample opportunity to review the PSR with counsel. The court also determined that the verification requirement of Rule 32 was met and that there was no plain error. The Fifth Circuit affirmed the sentence. View "United States v. Villafana-Mondragon" on Justia Law

An Indiana prisoner, while serving a 65-year sentence for murder, attacked a correctional officer at the Miami Correctional Facility in 2022. The attack caused serious injuries requiring outside medical treatment. Following an administrative hearing, the prisoner was found guilty of battering staff and was sanctioned by losing nearly 19 years of accumulated good time credits. The hearing officer based the sanction on the severity of the attack and the resulting injury and checked factors including the seriousness of the offense and the disruption to facility security.The prisoner filed a pro se habeas petition under 28 U.S.C. § 2254 in the United States District Court for the Southern District of Indiana, raising due process and Eighth Amendment claims. He alleged procedural errors, hearing officer bias, and that there was no evidence of serious injury. He also argued that the sanction was grossly disproportionate. After counsel was appointed, he submitted a brief that referenced, but did not fully restate, these claims. The district court denied relief, holding that the due process claims lacked merit and that the Eighth Amendment claim was waived due to insufficient argument in the brief.On appeal, the United States Court of Appeals for the Seventh Circuit held that the relevant constitutional claims were not waived, as the amended filing preserved the original petition’s arguments. The Seventh Circuit affirmed the district court’s judgment, holding that the hearing officer’s finding of serious bodily injury was supported by sufficient evidence under the “some evidence” standard. The court also concluded that the loss of good time credits was not grossly disproportionate in violation of the Eighth Amendment, given the circumstances of the offense, the petitioner’s disciplinary record, and the nature of his underlying conviction. The district court’s judgment was affirmed. View "Hawkins v. Sevier" on Justia Law