Justia Criminal Law Opinion Summaries

An armed and masked individual entered a pharmacy in Columbia Falls, Montana, and demanded Percocet 10 from three employees. The perpetrator directed the employees into a bathroom and fled after receiving the drugs. One employee, who knew Grant West personally, identified him as the robber based on his voice and limp, which matched surveillance footage. Police responded swiftly, arrested West at his residence, and found Percocet 10 in his pocket, along with shoes and a handgun resembling those seen in the surveillance video. West denied involvement, stating he had lent his vehicle to a friend and explaining his prescription history.The State charged West with robbery, aggravated kidnapping, and criminal possession of dangerous drugs in the District Court of the Eleventh Judicial District, Flathead County. Before trial, the State disclosed that its key identifying witness had a hearing impairment. West’s motion to exclude this testimony for delayed disclosure was denied by the District Court. During trial, the jury heard evidence from pharmacy employees, law enforcement, and others. West moved to dismiss for insufficient evidence after the State's case, but the motion was denied. The jury found West guilty on all counts and he was sentenced to prison.The Supreme Court of the State of Montana reviewed five issues raised on appeal: the Brady claim regarding witness hearing impairment, sufficiency of the robbery evidence, alleged prosecutorial misconduct, ineffective assistance of counsel, and cumulative error. The court held that the delayed disclosure of the witness’s impairment did not undermine the verdict, that sufficient evidence supported the robbery conviction, that the prosecutor’s conduct did not prejudice West’s substantial rights, and that the ineffective assistance claims were not record-based and thus not reviewable on direct appeal. No cumulative error was found. The Supreme Court of Montana affirmed the District Court’s judgment. View "State v. West" on Justia Law

Lewis Vanalen Borek was arrested for felony driving under the influence following a car accident in Star, Idaho. Officers at the scene administered a breathalyzer test, which returned a reading of .000, but Borek showed signs of impairment during field sobriety tests and admitted to taking anti-depressant medication. Subsequent blood tests revealed the presence of prescription drugs for mental health conditions. The State obtained records from the Idaho Prescription Monitoring Program (PMP), Ada County Jail, and Star Pharmacy, which included information about Borek’s prescriptions, medical history, and treatment.Borek initially moved to suppress all evidence from his arrest, arguing that officers lacked probable cause for a felony DUI, citing Idaho constitutional protections. The District Court denied his motion, but Borek appealed. The Idaho Court of Appeals reversed, agreeing that there was no probable cause for a felony DUI, and suppressed both the blood test results and statements made by Borek to medical staff. On remand, after further motions, the District Court allowed the State to obtain medical and prescription records from various sources. Borek filed a motion in limine to exclude these records, arguing they were privileged under Idaho Rule of Evidence 503. The District Court granted Borek’s motion, finding the records to be confidential communications protected by the psychotherapist-patient privilege.The Supreme Court of the State of Idaho reviewed the District Court’s order on permissive appeal. It held that the PMP and Star Pharmacy records did not constitute confidential communications under Rule 503(b)(2) and that Borek failed to meet his burden to prove that the Ada County Jail medical questionnaire was privileged. However, the State waived its challenge to exclusion of other jail records. The Supreme Court reversed the District Court’s order granting Borek’s motion in limine and remanded for further proceedings. View "State v. Borek" on Justia Law

Ronald Heath was sentenced to death for the 1989 murder of Michael Sheridan in Alachua County, Florida. Heath and his brother Kenneth conspired to rob Sheridan after meeting him at a bar, and the crime escalated when Heath stabbed Sheridan and instructed Kenneth to shoot him. Evidence at trial included testimony from Kenneth and physical evidence linking Heath to the victim’s property. The jury convicted Heath of first-degree murder and related offenses, recommending death by a vote of ten to two. The trial court imposed the death sentence, finding aggravating circumstances outweighed mitigating factors.Following affirmance of his conviction and sentence by the Supreme Court of Florida and denial of certiorari by the United States Supreme Court, Heath pursued multiple postconviction challenges in state and federal courts, all of which were unsuccessful. After his death warrant was signed in January 2026, Heath filed a second successive motion for postconviction relief in the Circuit Court of Alachua County. He raised claims regarding Florida’s lethal injection protocol, secrecy in clemency proceedings, his psychological age due to traumatic incarceration, and the nonunanimous jury recommendation. The circuit court summarily denied all claims and associated public records requests.The Supreme Court of Florida reviewed Heath’s appeal and habeas petition. It affirmed the circuit court’s summary denial of postconviction relief and public records requests, finding Heath’s claims were either speculative, procedurally barred, untimely, or insufficient under relevant legal standards. The Court held Heath failed to demonstrate a substantial and imminent risk with the execution protocol, did not raise a colorable clemency claim, and was not entitled to relief based on psychological age or nonunanimous jury vote. The Court also denied Heath’s habeas petition and his motion for a stay of execution. View "Ronald Palmer Heath v. State of Florida" on Justia Law

Two masked men entered a restaurant in Sussex County, Delaware, where one stole jewelry from a patron and the other fatally shot two individuals. The State alleged that Yony Morales-Garcia was the shooter, acting to protect his brother, Emner Morales-Garcia, who confessed to the robbery. The brothers were indicted on multiple charges and scheduled for separate trials. Emner accepted a plea deal, pleading guilty to first-degree robbery and second-degree conspiracy. Yony’s first trial ended in a hung jury, but in a second trial, he was convicted on all counts, including two for first-degree murder.The Superior Court of the State of Delaware presided over both trials, ultimately entering convictions against Yony following the second trial. At trial, the prosecution referenced Emner’s guilty plea both during opening statements and through a detective’s testimony, even though Emner was not called by the State as a witness in its case-in-chief. Yony’s defense objected on appeal, arguing that these references amounted to prosecutorial misconduct and, alternatively, that the court erred by failing to instruct the jury on the limited relevance of Emner’s plea.The Supreme Court of the State of Delaware found that the State’s repeated references to Emner’s guilty plea constituted prosecutorial misconduct, violating the principles articulated in Allen v. State regarding the improper use of a co-defendant’s guilty plea as substantive evidence. The Court held that this misconduct was plain error, prejudiced the fairness of the trial, and created a reasonable probability that the outcome would have been different absent the error. The Supreme Court of Delaware reversed Yony’s convictions and remanded the case for a new trial. View "Morales-Garcia v. State" on Justia Law

In this case, the defendant was charged with murder, burglary in the first degree, conspiracy to commit burglary in the first degree, and tampering with physical evidence, arising from the killing of a woman with whom he had an intimate relationship. The prosecution alleged that, following the discovery of the victim’s decomposed body, police conducted three interviews with the defendant. After waiving his Miranda rights in the second interview, he made incriminating statements and then said he was “done talking.” The next morning, while awaiting arraignment, the defendant initiated a third interview, again waived Miranda rights, and admitted to the killing.The trial took place in the Superior Court, judicial district of Waterbury, where a jury found the defendant guilty of all charges except conspiracy to commit tampering with physical evidence, which the court vacated at sentencing. The defense moved to suppress statements from the third interview, arguing the police had failed to clarify the defendant’s equivocal request for counsel under Connecticut law, and to suppress cell phone records as unsupported by probable cause and lacking particularity. The court denied these motions.On direct appeal, the Connecticut Supreme Court reviewed the trial court’s rulings. The Supreme Court held that any Miranda-based challenge to the admission of the second interview was waived by defense counsel, who had limited objections to the third interview only. Regarding the third interview, the Court found that rereading Miranda warnings and obtaining a written waiver sufficiently clarified the defendant’s equivocal request for counsel, satisfying State v. Purcell. The Court also determined the warrant for cell phone records was supported by probable cause and was sufficiently particular. The judgment of the Superior Court was affirmed. View "State v. Johnson" on Justia Law

Steve Boria was indicted for leading a gang involved in distributing narcotics and committing violent acts. He distributed crack cocaine and was involved in a firearm discharge. After most co-defendants pleaded guilty, Boria opted to plead guilty as well. On the night before his plea hearing, he took medications for sleeping problems and bipolar disorder. During the plea colloquy before the United States District Court for the Southern District of New York, the magistrate judge inquired about his medication use, confirmed he felt clearheaded, and verified his understanding of the proceedings. Both defense counsel and the government had no objections to Boria’s competence. Boria responded cogently to the court’s questions and the court found his plea voluntary and knowing, subsequently sentencing him to fifteen years.Boria’s counsel failed to file a timely notice of appeal after sentencing. The district court found this constituted ineffective assistance of counsel, vacated the judgment, and re-entered it to allow Boria to appeal. Boria then timely appealed the amended judgment.The United States Court of Appeals for the Second Circuit reviewed the case. The court held that the district court did not violate Federal Rule of Criminal Procedure 11 or Boria’s constitutional rights. The appellate court found the district court’s inquiry sufficient to ensure Boria’s understanding and voluntariness of the plea, as Boria’s conduct during the hearing raised no concerns regarding his competency. Additionally, the Second Circuit determined that Boria failed to show plain error, as there was no reasonable probability he would not have pleaded guilty but for the alleged procedural error. Accordingly, the Second Circuit affirmed the judgment of the district court. View "United States v. Boria" on Justia Law

Charlie Holley lived in a Florida City townhouse and was involved in a violent incident on June 21, 2021. Armed with a scoped assault rifle, Holley threatened neighbors and a visiting relative, then pointed the rifle at Charlotte Wicker, a United States Postal Service mail carrier, and fired at her vehicle. The situation led to multiple 911 calls, a large police response, and Holley’s eventual arrest after he barricaded himself inside his home. Subsequent searches found weapons and ammunition, and ballistics confirmed the rifle had been fired.A federal grand jury in the Southern District of Florida indicted Holley on five counts, including attempted murder and assault of a federal employee, brandishing and discharging a firearm in furtherance of a crime of violence, and possession of a firearm and ammunition as a felon. Holley underwent several psychiatric evaluations and was found incompetent to stand trial twice, but after further treatment, he was ultimately deemed competent. At trial in the United States District Court for the Southern District of Florida, Holley objected to the introduction of several body-worn camera clips and a 911 call, arguing these violated evidentiary rules and the Confrontation Clause. The district court admitted the evidence, finding it relevant to the police response and not unfairly prejudicial, and gave limiting instructions to the jury.After the jury convicted Holley on all but the attempted murder count, the district court sentenced him to 192 months’ imprisonment, considering both his criminal history and mental health issues. The United States Court of Appeals for the Eleventh Circuit reviewed Holley’s challenges to the admissibility of the evidence and his sentence. The court held that the evidentiary rulings were within the district court’s discretion and that the sentence was reasonable and adequately considered Holley’s mental health. The Eleventh Circuit affirmed both the convictions and sentence. View "USA v. Holley" on Justia Law

Dameia Smith, an IRS tax examining clerk, was involved in a series of criminal acts beginning with the armed robbery of a restaurant employee in September 1998. After learning that the victim was cooperating with authorities, Smith accessed the IRS database to obtain her address and expressed intentions to prevent her from testifying, including stating he would kill her. In January 1999, Smith drove to the victim’s home with a firearm and attempted to persuade a friend to kill her; when the friend refused, Smith coerced him into an attempted bank robbery. The plan failed, and Smith was arrested after his friend began cooperating with law enforcement.Smith was tried in the United States District Court for the Eastern District of Pennsylvania on six counts, including Hobbs Act robbery, unauthorized computer access, solicitation to commit murder of a federal witness, attempted murder of a federal witness, and using a firearm during and in relation to a crime of violence under 18 U.S.C. § 924(c). The jury initially convicted Smith only of unauthorized computer access, but on retrial, convicted him on all charges. Smith’s § 924(c) conviction was predicated on either solicitation or attempted murder, with a general verdict form not specifying which. The District Court imposed a lengthy sentence and later denied Smith’s motion for relief under 28 U.S.C. § 2255, finding attempted murder of a federal witness was a crime of violence under the elements clause. Subsequent remands and appeals followed Supreme Court decisions narrowing the scope of qualifying predicates for § 924(c).On appeal, the United States Court of Appeals for the Third Circuit held that attempted murder of a federal witness categorically qualifies as a “crime of violence” under 18 U.S.C. § 924(c)'s elements clause because it necessarily requires proof of the attempted use of physical force. The court also found no reasonable probability that Smith’s § 924(c) conviction was based solely on solicitation, an invalid predicate, rendering any instructional error harmless. The Third Circuit affirmed the District Court’s denial of relief. View "USA v. Smith" on Justia Law

GEICO and its subsidiaries brought a lawsuit in the United States District Court for the Eastern District of New York against Dr. Bhargav Patel and his medical practice, alleging that the defendants engaged in a scheme to defraud GEICO by manipulating New York’s no-fault automobile insurance system. GEICO claimed that from 2019 to 2023, defendants submitted approximately $3.4 million in reimbursement claims for treatments that were unnecessary, experimental, excessive, illusory, or not provided at all. These claims allegedly resulted from a fraudulent scheme involving kickbacks for patient referrals and the provision of services by unlicensed individuals or contractors.After GEICO initiated its federal action, the defendants responded by filing over 600 collection actions in New York state courts and arbitration tribunals, seeking recovery for disputed or denied claims totaling more than $2 million. GEICO, facing the prospect of fragmented litigation and the risk of inconsistent judgments, sought a preliminary injunction from the district court to stay all pending state and arbitration proceedings and to prevent the defendants from filing new collection actions until the federal court resolved the RICO claims. The district court granted the injunction, finding that GEICO had demonstrated irreparable harm, serious questions going to the merits, and a balance of hardships tipping in GEICO’s favor. The court also determined it had authority under the “in aid of jurisdiction” exception to the Anti-Injunction Act to enjoin the parallel proceedings.On appeal, the United States Court of Appeals for the Second Circuit reviewed the district court’s decision for abuse of discretion and found none. The appellate court held that the preliminary injunction was justified by the real risk of irreparable harm to GEICO posed by inconsistent judgments and the inability to fully adjudicate the alleged fraudulent scheme in piecemeal state actions. The Second Circuit further held, consistent with its recent precedent in State Farm Mutual Automobile Insurance Company v. Tri-Borough NY Medical Practice, P.C., that the injunction did not violate the Anti-Injunction Act because it was expressly authorized under RICO. The court affirmed the district court’s order. View "GEICO v. Patel" on Justia Law

A man was accused of surreptitiously recording his 13-year-old stepdaughter with his cellphone while she was undressing in the bathroom. His wife reported the incident to police, providing video evidence from a hidden camera that appeared to show him engaging in inappropriate conduct outside his stepdaughters’ bedrooms. Detectives confronted the man at his workplace, and after he indicated he wanted a lawyer, he handed over his cellphone when asked by police. The officers immediately informed him they were seizing the device but did not search it until obtaining a warrant the next day. Upon searching the phone, police found incriminating photos and videos, leading to a grand jury indictment on charges including video voyeurism and sexual exploitation of a child.The District Court of the Fourth Judicial District, Ada County, reviewed the defendant’s motion to suppress the cellphone and its contents, arguing the seizure was a Fourth Amendment violation due to the lack of a warrant or valid exception. At a suppression hearing, the court heard testimony from the detective about his concern that evidence could be quickly deleted if the phone was not seized immediately. The district court denied the motion to suppress, concluding that exigent circumstances justified the warrantless seizure because of the imminent risk that evidence would be destroyed.On appeal, the Supreme Court of the State of Idaho reviewed the district court’s denial of the motion to suppress. The Idaho Supreme Court held that the warrantless seizure of the cellphone was justified under the Fourth Amendment’s exigent circumstances exception due to the risk of imminent destruction of evidence. The court clarified that this exception applied based on the totality of the circumstances and did not create a per se rule for all cellphone cases. The judgment of the district court was affirmed. The court also found that any issues regarding parole conditions were moot due to their removal from the amended judgment. View "State v. Smith" on Justia Law