Justia Criminal Law Opinion Summaries

The defendant faced four criminal charges in separate cases—three for theft (shoplifting) and one for interference with official acts following an arrest. As part of a single plea agreement, he pled guilty to two theft charges; in return, the State dismissed the remaining two cases, with the defendant agreeing to pay costs in the dismissed cases. The Iowa District Court for Polk County sentenced the defendant in the two theft cases, dismissed the other two, and ordered him to pay costs for the dismissed cases, including indigent defense recoupment and filing fees.After the district court’s dispositional orders, the defendant appealed, challenging the court’s authority to assess costs in the dismissed cases. The Iowa Supreme Court granted discretionary review to address this issue. The State conceded that no statute authorized the district court to impose costs in dismissed criminal cases. The Supreme Court examined relevant statutory provisions, noting that neither Chapter 815 nor Chapter 910 of the Iowa Code allows for assessment of costs against a defendant when a case is dismissed, as such authority was repealed in 2012.The Iowa Supreme Court held that parties cannot confer statutory authority on the court through a plea agreement for a disposition not authorized by statute. Accordingly, the district court’s orders assessing costs in the dismissed cases were ultra vires and invalid. The Supreme Court vacated the convictions, sentences, and dispositional orders, and remanded the cases. On remand, the State may elect either to vacate only the unauthorized cost orders while enforcing the remainder of the plea bargain, or to vacate the entire plea agreement and all resulting orders, with the option to reinstate any dismissed charges. View "State of Iowa v. Pagliai" on Justia Law

The case concerns the prosecution of a father charged with first and third degree sexual assault of his 5-year-old biological daughter. The child disclosed the alleged abuse to her older brother, who then informed their mother. The day after the disclosure, the father visited the mother’s home and, upon hearing the brother repeat the accusation, physically assaulted and threatened to kill the brother if he repeated the allegation. The mother delayed reporting the incident to law enforcement for about a month. During pretrial proceedings, the court excluded evidence of another accusation involving a different child but permitted testimony about the father's assault and threat against the brother.Following a jury trial in the District Court for Douglas County, the defendant was acquitted of first degree sexual assault but convicted of third degree sexual assault of a child and sentenced to imprisonment and post-release supervision. He appealed to the Nebraska Court of Appeals, arguing that admission of evidence regarding the assault and threat was unduly prejudicial under Neb. Rev. Stat. § 27-403. The Court of Appeals reversed the conviction, reasoning that omitting context about the accusation involving the other child created a misleading impression and unfairly prejudiced the defendant, warranting a new trial.On further review, the Nebraska Supreme Court found that the district court did not abuse its discretion in admitting evidence of the defendant’s assault and threat toward the brother. The Court held that this evidence was probative of consciousness of guilt and explained the mother’s delay in reporting the crime. It further determined that any omission regarding the other child’s accusation did not rise to the level of plain error, especially since defense counsel had sought its exclusion. The Supreme Court reversed the Court of Appeals’ decision and remanded with directions to affirm the conviction and sentence. View "State v. Cartwright" on Justia Law

The defendant killed his former high school girlfriend by strangling and cutting her throat after their relationship ended. In the months leading up to the crime, he exhibited signs of emotional distress and had several altercations with the victim and others. On the day of the killing, he took calculated steps to conceal his involvement, including moving the victim’s body, cleaning evidence, and misleading police about their interactions. During trial, the defendant admitted to the killing but argued he was not criminally responsible due to mental illness, presenting expert testimony regarding his psychological state.In the Superior Court, the defendant was convicted of first-degree murder on theories of deliberate premeditation and extreme atrocity or cruelty, along with assault and battery charges. He was sentenced to life without parole. After his conviction, he filed a motion to suppress evidence obtained from searches of his home and vehicle, arguing lack of probable cause, which the court denied. Later, he moved for a new trial, citing newly discovered evidence of developing schizophrenia after the crime. After an evidentiary hearing, a Superior Court judge denied the motion, finding the new evidence did not cast real doubt on the justice of the conviction.The Supreme Judicial Court of Massachusetts reviewed the consolidated appeals from the convictions and denial of the new trial motion. The court held that the lower court did not err or abuse its discretion in denying the new trial or in its evidentiary rulings. It also found the denial of the suppression motion proper, concluding the warrants were supported by probable cause. The court affirmed all convictions and the denial of the new trial motion. However, it held that the sentence of life without parole was unconstitutional for defendants under twenty-one and remanded for resentencing to life with parole eligibility after fifteen years. View "Commonwealth v. Fujita" on Justia Law

A man was stopped by a police officer for a window tint violation while riding as a passenger in a vehicle driven by a family acquaintance. During the stop, the officer observed behavior from the man that suggested narcotics use. The officer searched a bag in the vehicle, which the man identified as his, and found what appeared to be crystal methamphetamine and a used methamphetamine pipe. The man was arrested at the scene, and the driver left. The man was subsequently indicted for possession of methamphetamine, and at trial, he testified that the drugs were not his and that he did not know the driver well, though she was a family friend.At trial in the Circuit Court of Madison County, the State presented evidence including the testimony of the arresting officer and a crime lab analyst. The defendant’s only witness was himself. In closing argument, the prosecutor highlighted that the defendant, who blamed the drugs on the driver, had not called her as a witness, even though she was known to him and accessible through family. The jury found the defendant guilty, and the trial court denied post-trial motions for a judgment notwithstanding the verdict or a new trial.On appeal to the Supreme Court of Mississippi, the defendant argued that the prosecutor’s comments in closing were improper because they referenced his failure to call the driver as a witness. The Supreme Court reviewed the claim for plain error, since no objection was made at trial. The Court held that there was no error because the witness was more available to the defendant than to the State, given her relationship to the defendant’s family. The conviction and sentence were affirmed. View "Hollingsworth v. State of Mississippi" on Justia Law

In December 2022, Mariah Karriem was attacked outside a hookah lounge in Lowndes County, Mississippi by three individuals, including Kierra Wallace, her sister, and her cousin. Karriem was punched, kicked, and struck several times with a glass bottle, sustaining minor injuries that required minimal medical treatment. The attack was recorded on video, and Karriem later identified her assailants as they fled the scene. A longer video of the incident and a Facebook Live recording of Wallace and her sister admitting to the assault were admitted into evidence.The case was tried before the Lowndes County Circuit Court, where the jury found Wallace guilty of aggravated assault. She was sentenced to twenty years in the custody of the Mississippi Department of Corrections, with five years suspended and five years of post-release supervision. Following sentencing, Wallace filed a motion for judgment notwithstanding the verdict or for a new trial, arguing, among other things, that newly discovered video evidence exculpated her. The trial court held a hearing and found the new video was cumulative of evidence already presented and not exculpatory, denying the motion.On appeal, the Supreme Court of Mississippi reviewed Wallace’s claims regarding a defective indictment, constructive amendment of the indictment, sufficiency of the evidence, and denial of the motion for a new trial. The Court held that the indictment was not defective, as it did not conflate intent elements and Wallace’s defense was not prejudiced. The Court found Wallace was estopped from challenging a jury instruction due to the invited-error doctrine. Reviewing the evidence de novo, the Court found it sufficient for a rational juror to convict. It also held the trial court did not abuse its discretion in denying a new trial. The conviction was affirmed. View "Wallace v. State of Mississippi" on Justia Law

A former elected county prosecutor in Kentucky’s 21st Judicial Circuit was charged with Honest Services Wire Fraud, violations of the Travel Act, and Federal Program Bribery. The charges stemmed from an arrangement with a young woman, M.H., who repeatedly faced legal troubles. Evidence showed that the prosecutor agreed to help her with matters such as getting warrants withdrawn, charges reduced, and release from jail, in exchange for sexual acts and explicit images. The FBI discovered the scheme, leading to federal prosecution. At trial, the government presented incriminating text messages, testimony from M.H., and law enforcement, while the defendant claimed he did not solicit images and that M.H. was assisting in investigations—a claim disproved by evidence.The United States District Court for the Eastern District of Kentucky oversaw the jury trial, which resulted in convictions on all counts. The court sentenced the defendant to 41 months in prison and imposed supervised release conditions, including refraining from excessive alcohol use. On appeal to the United States Court of Appeals for the Sixth Circuit, the defendant challenged the exclusion of certain testimony about Kentucky law, sufficiency of the evidence on several elements, the federal funding nexus for the bribery charge, the supervised release condition, and the sentencing court’s refusal to consider “collateral consequences.”The Sixth Circuit held that the district court did not abuse its discretion or violate constitutional rights in excluding expert legal opinion testimony and that the jury was properly instructed on the meaning of “official acts.” The court found overwhelming evidence supporting the verdict, including proof of a quid pro quo and an interstate nexus. The federal funding requirement was satisfied by evidence that the state received sufficient funds. The supervised release condition and sentencing decisions were not plainly erroneous. The Sixth Circuit affirmed the district court’s judgment in all respects. View "United States v. Goldy" on Justia Law

In this case, federal prosecutors charged several members of the Junk Yard Dogs, a Memphis-area gang affiliated with the Almighty Vice Lord Nation, with racketeering, murder, attempted murder, and firearms offenses stemming from a violent gang war in the summer of 2020. The indictment followed a spree of shootings that injured multiple people and left one dead. Of the fifteen indicted, most pled guilty, but Tomarcus Baskerville (gang leader), Thomas Smith (second-in-command), and Courtland Springfield (foot soldier) went to trial. Extensive evidence at trial included testimony from cooperating codefendants, phone records, and physical evidence linking the defendants to coordinated attacks against rival gangs.The United States District Court for the Western District of Tennessee presided over the trial. After lengthy deliberations, the jury convicted Baskerville, Smith, and Springfield on various racketeering and violent crime counts. There were challenges during deliberations related to suspected jury intimidation, but after polling jurors and interviewing the foreperson, the district court found the jury remained impartial and denied motions for mistrial. Springfield was acquitted of certain charges, and another defendant was acquitted entirely.The United States Court of Appeals for the Sixth Circuit reviewed the convictions and sentences. The court affirmed all convictions, finding the evidence sufficient and rejecting arguments for mistrial or the necessity of individual juror questioning. The court held that the district court did not abuse its discretion in handling jury intimidation claims and properly admitted the government’s phone chart exhibits. However, consistent with the government’s concession, the Sixth Circuit vacated Smith’s sentence related to his firearm conviction and remanded for resentencing, ruling that the mandatory minimum sentence imposed exceeded what the jury’s findings supported under federal law. View "United States v. Baskerville" on Justia Law

Jason Florence, while on supervised release for a prior federal child pornography conviction, was found in possession of a smartphone containing child pornography during an unscheduled home visit by his probation officer. The conditions of his supervised release prohibited him from possessing such devices without his probation officer's knowledge. A forensic analysis of the confiscated phone revealed over one hundred images and two videos of child pornography, some accessed shortly before the search. Florence admitted ownership of the phone and provided its passcode, and other evidence linked him to the device and the illicit materials.This case was tried before the United States District Court for the Western District of Kentucky. The parties stipulated to Florence’s prior convictions and the terms of his supervised release. After a two-day trial, a jury convicted Florence of possessing child pornography and found that the material depicted minors under 12 years old. At sentencing, the district court determined that Florence’s prior conviction triggered a statutory mandatory minimum sentence of ten years’ imprisonment under 18 U.S.C. § 2252A(b)(2), and imposed a life term of supervised release. Florence objected, arguing that Fifth and Sixth Amendment rights required the jury to find the fact of his prior conviction, and he challenged the admission of his probation officer’s credibility testimony and the reasonableness of his sentence.On appeal, the United States Court of Appeals for the Sixth Circuit held that the district court did not err in finding the fact of Florence’s prior conviction and applying the mandatory minimum, citing the narrow exception in Almendarez-Torres v. United States, which allows a judge to find the fact of a prior conviction. The court found any error in admitting the probation officer’s credibility testimony harmless, given the overwhelming evidence of guilt. Finally, the Sixth Circuit held that the life term of supervised release was both procedurally and substantively reasonable. The judgment of the district court was affirmed. View "United States v. Florence" on Justia Law

The defendant operated an immigration services business, preparing self-petition visa applications under the Violence Against Women Act (VAWA) for clients who claimed abuse by U.S. citizen or lawful permanent resident spouses. Investigators found that the defendant submitted applications containing forged psychological evaluations—some altered from a psychologist’s prior reports—and fabricated residential lease documents for multiple clients. These documents were used as evidence to satisfy VAWA eligibility criteria, such as establishing residence and proof of abuse. The defendant was not a licensed attorney and did not sign the applications as preparer.The United States District Court for the District of Maryland presided over the defendant’s trial. After the government presented its case, the defendant moved for judgment of acquittal, arguing that the fraudulent documents were not “required” by immigration law and that the statute required submission under oath, which he claimed was not satisfied. The district court denied the motion, ruling that while the regulations did not mandate specific documents, any evidence submitted to establish eligibility became “required” for that application. The jury subsequently convicted the defendant on all counts, and he was sentenced to 57 months’ imprisonment and two years of supervised release. The defendant did not renew his acquittal motion and later appealed, challenging the sufficiency of the evidence for several counts and alleging a sentencing error based on a discrepancy between oral and written conditions of supervised release.The United States Court of Appeals for the Fourth Circuit affirmed the district court’s judgment and sentence. The court held that documents submitted to establish eligibility in VAWA self-petitions—including psychological evaluations and lease agreements—constitute “required” documents under 18 U.S.C. § 1546(a) once chosen and presented. It further held that the statute’s “knowingly presents” clause does not require an oath for criminal liability. Regarding sentencing, the court found no material discrepancy between oral and written supervised release conditions and concluded that resentencing was not warranted. View "US v. Aborisade" on Justia Law

Christopher Texidor was charged alongside several codefendants for participating in a large-scale drug trafficking organization that conspired to ship nearly 3,000 kilograms of marijuana from California to Pennsylvania using the United States Postal Service. Texidor used his business, Fastlane Auto Sales, LLC, and his residence to facilitate these activities. He recruited various individuals, including family members, to receive shipments and organized GPS tracking for parcels after noticing thefts. When the group determined a postal employee was responsible for stealing their parcels, Texidor and others organized violent acts to intimidate him, including drive-by shootings and theft of the employee’s vehicle containing drugs and a firearm. During searches, law enforcement discovered drugs, tracking devices, firearms, and cash at Texidor’s properties. Texidor was also separately indicted for wire fraud involving false Paycheck Protection Program loan applications, which he committed while on pretrial release.Following a six-day trial in the U.S. District Court for the Middle District of Pennsylvania, a jury convicted Texidor on most drug and firearm counts, but acquitted him of the cocaine charge and a related firearm count. Texidor later pleaded guilty to one count of wire fraud, with other fraud charges dismissed. The District Court considered both cases at sentencing, calculated a Guidelines range of 292–365 months, and imposed concurrent sentences: 292 months for the drug/firearm offenses and 240 months for wire fraud. The District Court struck one reference to cocaine from the Presentence Investigation Report but overruled objections to other references and applied a four-level leadership enhancement.The U.S. Court of Appeals for the Third Circuit affirmed the District Court’s rulings. It held that recent changes to the Sentencing Guidelines do not prevent consideration of acquitted conduct when determining an appropriate sentence outside of Guidelines calculations. The Court found no clear error in applying the leadership enhancement and concluded that the aggregate sentence was substantively reasonable. Further, under the concurrent sentence doctrine, the Court declined to review the substantive reasonableness of the wire fraud sentence. View "USA v. Texidor" on Justia Law