Justia Criminal Law Opinion Summaries

The defendant, a former employee of a tattoo studio, embezzled approximately $120,000 from her employer over a nine-month period. After being charged with first-degree theft, she pleaded guilty under a plea agreement in which both she and the State recommended a deferred judgment, with restitution payments as a condition of probation. Prior to sentencing, a presentence investigation report (PSI) was submitted, but it did not include any victim-impact statements. At the sentencing hearing, the business owner delivered an oral victim-impact statement detailing the emotional and financial harm caused by the theft. The district court declined to follow the parties’ joint recommendation and instead imposed the statutory maximum prison sentence of up to ten years.The defendant appealed to the Iowa Court of Appeals, arguing that the district court abused its discretion by sentencing her to prison and by allegedly relying on improper factors contained in the victim-impact statement, which she claimed included unproven allegations. The Court of Appeals affirmed the district court’s judgment, holding that the defendant had not preserved error regarding the victim-impact statement because she failed to object at the sentencing hearing. The appellate court also found no indication that the district court had relied on improper factors.Upon further review, the Supreme Court of Iowa vacated the Court of Appeals’ decision. The Supreme Court clarified that, with respect to previously unseen oral victim-impact statements delivered at sentencing, defendants are not required to object contemporaneously in order to raise claims on direct appeal about improper sentencing considerations. However, the Supreme Court concluded that the victim-impact statement in this case was largely appropriate and that the record did not indicate the district court relied on any improper factors. The Supreme Court affirmed the district court’s judgment and sentence. View "State of Iowa v. Hallock" on Justia Law

Trevor M. Jones was charged with theft by deception in November 2023. Almost a year after the charge was filed, Jones moved for absolute discharge, claiming that the State of Nebraska failed to bring him to trial within the time required by Nebraska’s statutory speedy trial provisions. The District Court for Lancaster County held a hearing and agreed that Jones’s statutory speedy trial rights had been violated, granting his motion for absolute discharge and dismissing the charge.Following this decision, the State sought to appeal the district court’s order. Instead of following the procedures set out for exception proceedings under Neb. Rev. Stat. § 29-2315.01, which specifically governs State appeals in criminal cases, the State simply filed a notice of appeal under the general appellate statute, Neb. Rev. Stat. § 25-1912. The Nebraska Court of Appeals questioned whether it had jurisdiction, since the State had not complied with the specific procedural requirements for exception proceedings. After seeking input from the State and considering a motion for summary dismissal from Jones, the Court of Appeals dismissed the appeal, finding that the State’s failure to follow the statutory process deprived the appellate court of jurisdiction. The State’s motion for rehearing was denied.The Nebraska Supreme Court reviewed the matter on further review. The Supreme Court held that, under established precedent and the doctrine of stare decisis, the State may only obtain appellate review of a district court’s order granting absolute discharge in a criminal case by strictly following the procedures outlined in § 29-2315.01. The State’s failure to do so meant the appellate courts lacked jurisdiction to hear the appeal. The Supreme Court affirmed the Court of Appeals’ dismissal of the State’s appeal. View "State v. Jones" on Justia Law

The defendant was convicted by a jury of first degree murder, use of a deadly weapon to commit a felony, and possession of a deadly weapon by a prohibited person. Following affirmance of his convictions on direct appeal, he filed a timely motion for postconviction relief, alleging ineffective assistance of counsel and a Brady violation based on counsel’s failure to present exculpatory evidence and a witness. The defendant submitted three documents on the same day: his motion, a memorandum brief with an affirmation concerning the brief, and a separate affirmation, filed with a motion for appointment of counsel, that expressly verified the facts in his postconviction motion.The District Court for Hall County denied postconviction relief without an evidentiary hearing, citing two independent grounds: lack of verification and substantive defects in the motion. The court interpreted the affirmation attached to the memorandum brief as not verifying the motion for postconviction relief and did not address the effect of the separate affirmation attached to the motion for appointment of counsel. Alternatively, the court found that the defendant’s claim was insufficient on the merits, characterizing the allegations as mere conclusions of fact or law without supporting facts.On appeal, the Nebraska Supreme Court reviewed the case for plain error because the defendant’s brief failed to properly assign errors as required by court rules. The Supreme Court held that a separate, properly executed verification, filed simultaneously with a postconviction motion and directed exclusively to that motion, satisfies the statutory verification requirement. However, the court found no plain error in the District Court’s denial of relief, concluding that the defendant’s motion did not allege sufficient facts to warrant an evidentiary hearing. Accordingly, the Nebraska Supreme Court affirmed the denial of postconviction relief. View "State v. Anthony" on Justia Law

After a traffic collision, the defendant exited his vehicle—leaving his ten-year-old child alone inside, where a loaded but unchambered firearm was holstered in the front seat—and confronted the other driver. The defendant smashed the other driver’s window with a baton, then struck and kicked him multiple times after the driver exited his vehicle and fell to the ground. Several motorists witnessed the altercation and contacted authorities. The defendant departed before police arrived, but later called 911 and was arrested. During the arrest, he disclosed the presence of both his child and the firearm in his vehicle.The Superior Court (Edwards, J.) presided over the ensuing jury trial, in which the defendant was convicted of reckless conduct (for leaving his child unsupervised in a car with a gun), second degree assault (for striking with a baton), two counts of simple assault (for kicking), and criminal mischief. The defendant appealed three of these convictions, contending: that there was insufficient evidence for reckless conduct; that the trial court erred in instructing the jury on self-defense for the second degree assault charge; and that the court wrongly refused a specific unanimity instruction for the simple assault charge.The Supreme Court of New Hampshire reviewed the case. It determined that the evidence was legally insufficient to support the reckless conduct conviction, as no rational trier of fact could find beyond a reasonable doubt that the defendant consciously disregarded a substantial risk to his child. The court held that the self-defense instruction for second degree assault improperly directed the jury regarding the element of deadly force and thus constituted reversible error. Finally, it found that the court's refusal to give a specific unanimity instruction on the simple assault charge was also reversible error. Accordingly, the Supreme Court of New Hampshire reversed the convictions for reckless conduct, second degree assault, and simple assault, and remanded the latter two for further proceedings. View "State v. Price" on Justia Law

Kent Parris was apprehended after selling fentanyl, methamphetamine, and drug paraphernalia to a confidential informant during a law enforcement sting operation near a church. Following the transaction, Parris fled in his vehicle but was eventually stopped by officers, who found marked bills and various drugs on his person and in his car. During a search along the route of the brief vehicle chase, police recovered a bag containing methamphetamine and a backpack with a loaded handgun and additional pills. At trial, evidence included audio recordings, body camera footage, physical drug evidence, and the items seized from Parris and the scene.The Arkansas County Circuit Court jury convicted Parris on multiple counts: possession of fentanyl and cocaine with intent to deliver, possession of drug paraphernalia to manufacture, delivery of methamphetamine and fentanyl, simultaneous possession of drugs and firearms, and theft by receiving a firearm. The jury imposed consecutive sentences totaling life plus 185 years, with an additional concurrent ten-year enhancement for committing drug crimes within one thousand feet of a church. Parris challenged the sufficiency of the evidence for several convictions and contested the enhancement.The Supreme Court of Arkansas reviewed the case and affirmed all convictions and the sentence enhancement except for the theft-by-receiving conviction. The court held that substantial evidence supported the drug-related convictions and the simultaneous possession charge, relying on both direct and circumstantial evidence. However, regarding theft by receiving, the court found that the only evidence the firearm was stolen was inadmissible hearsay from a police officer referencing a report. Concluding there was insufficient evidence that the firearm was stolen property, the court reversed the theft-by-receiving conviction and remanded the case to the circuit court for a new sentencing order. The remaining convictions and enhancements were affirmed. View "PARRIS v. STATE OF ARKANSAS" on Justia Law

A man was convicted by a jury of raping his then-girlfriend’s 14-year-old daughter, following evidence that included sexually explicit electronic messages he sent to the minor, testimony from the victim about the assault, and testimony from another of his daughters describing similar sexual abuse. The victim disclosed the assault to her mother immediately after it occurred, but her mother did not initially believe her or contact authorities. Several years later, the mother received messages from the defendant describing further sexual abuse of his other children; these messages ultimately led to the involvement of law enforcement and the defendant’s arrest and prosecution.The Garland County Circuit Court admitted the contested electronic messages into evidence, finding sufficient authentication through the testimony of the recipients. The court also allowed the defendant’s other daughter to testify to similar abuse under the “pedophile exception” to Arkansas Rule of Evidence 404(b), determining the testimony was more probative than prejudicial. The defendant moved for a continuance after being charged with additional sexual offenses days before trial, but the circuit court denied the motion, finding he was able to assist his counsel. After conviction, the court sentenced him to life in prison.On appeal to the Supreme Court of Arkansas, the defendant challenged the sufficiency of the evidence, the admission of the electronic messages and other-acts testimony, the denial of the continuance, and the constitutionality of his life sentence. The Supreme Court of Arkansas affirmed the conviction and sentence. It held that substantial evidence supported the jury’s finding that the defendant was in a position of authority over the victim as required by statute; the circuit court did not abuse its discretion in its evidentiary rulings or in denying the continuance; and the life sentence for child rape was not unconstitutional under either the Eighth Amendment or the Arkansas Constitution. View "FAULKNER V. STATE OF ARKANSAS" on Justia Law

On the night of May 26, 2023, Undra Williams entered the Inferno Sports Bar and Nightclub in Columbus, Mississippi, where he was seen on surveillance footage wearing orange and blue. After an initial exchange of words with Devan Thompson, Williams left and later returned to the club. Witnesses testified that Williams drew a gun and shot Thompson multiple times, resulting in Thompson’s death. Three bystanders suffered gunshot wounds. Several witnesses, some of whom personally knew Williams, identified him both in surveillance footage and in court as the shooter. Nine shell casings were recovered from the scene, but the weapon was never found. Williams turned himself in two days later.After a jury trial in the Lowndes County Circuit Court, Williams was convicted of first-degree murder and three counts of aggravated assault. The State retired a fourth count of aggravated assault. Williams was sentenced to life imprisonment for the murder and three consecutive twenty-year terms for the aggravated assault convictions. His post-trial motion for judgment notwithstanding the verdict, or alternatively for a new trial, was denied by the Circuit Court.On appeal to the Supreme Court of Mississippi, Williams argued that the convictions were against the overwhelming weight of the evidence, citing unreliable eyewitness testimony and a lack of physical evidence. The Supreme Court of Mississippi held that the convictions were supported by compelling testimonial and video evidence and that it is within the jury’s province to resolve questions of witness credibility and evidentiary weight. The Court found no abuse of discretion by the trial court in denying the motion for a new trial and affirmed Williams’s convictions and sentences. View "Williams v. State of Mississippi" on Justia Law

A state trooper observed David Davalos commit a traffic violation by failing to signal a lane change. The trooper initiated a stop as Davalos pulled into the driveway of the home he shared with his parents. The driveway was open, with no fence or gate, and was adjacent to a public sidewalk and street. After blocking Davalos’s car, the officer instructed Davalos to exit the vehicle, which he did, leaving the driver’s side door open. The officer, concerned for his safety and unable to see into the car due to heavily tinted windows, approached and smelled marijuana, saw ashes, and noticed the driver’s side door appeared tampered with. After Davalos admitted to recently smoking marijuana and possessing a small amount, the officer searched the car and discovered marijuana and a firearm.Davalos was charged with possession of a firearm by a convicted felon in the United States District Court for the Western District of Texas. Prior to trial, he moved to suppress the evidence from the warrantless search, arguing the search violated the Fourth Amendment because the car was within the home’s curtilage and no exigent circumstances existed. A magistrate judge found the driveway was not part of the curtilage and recommended denying the motion, concluding the officer had probable cause and exigent circumstances justified the search. The district court adopted this recommendation, and Davalos entered a conditional guilty plea preserving his right to appeal the suppression ruling.On appeal, the United States Court of Appeals for the Fifth Circuit held that the officer’s actions were permissible under the Fourth Amendment. The court found that probable cause and exigent circumstances justified the warrantless search of the car, regardless of curtilage questions, and affirmed the denial of Davalos’s motion to suppress. The judgment of the district court was affirmed. View "United States v. Davalos" on Justia Law

Eugene Lockhart pleaded guilty to conspiracy to commit wire fraud and bank fraud under federal law and was sentenced to 54 months in prison, followed by supervised release and joint restitution of over $2.4 million. Although Lockhart attempted to appeal pro se, his appeal was dismissed for lack of prosecution. Later, several of his codefendants successfully reduced their restitution obligations on appeal. Lockhart completed his supervised release in May 2017. In September 2023, he filed a petition for writ of coram nobis, seeking to vacate his conviction and restitution order, alleging ineffective assistance of counsel due to his attorney’s failure to appeal and preserve issues regarding restitution.The United States District Court for the Northern District of Texas denied Lockhart’s petition. The court found the petition untimely and determined it lacked jurisdiction to vacate the restitution order, reasoning that such a challenge could only be raised on direct appeal. The district court also concluded that Lockhart’s ineffective assistance claim did not warrant coram nobis relief because he had not diligently sought prompt relief after his supervised release ended.The United States Court of Appeals for the Fifth Circuit reviewed the district court’s decision, applying de novo review to jurisdictional issues and abuse of discretion to the denial of the writ. The Fifth Circuit clarified that a coram nobis petition may seek to vacate a conviction, and if granted, any related restitution order would be vacated as well. However, the court held that Lockhart failed to exercise reasonable diligence in seeking relief, as he waited over six years after his supervised release ended to file the petition without justification. Accordingly, the Fifth Circuit affirmed the district court’s denial of Lockhart’s writ of coram nobis. View "United States v. Lockhart" on Justia Law

The case centers on a defendant who was convicted by a jury of multiple offenses resulting from his involvement in a shootout with police officers in San Diego. During jury selection, the prosecution exercised a peremptory challenge to remove a prospective juror (Juror 1), who was believed to be a Latina, based on the prosecutor’s belief that she was confused about the concept of intent. The defendant objected, arguing that the peremptory challenge was being used to exclude Hispanic or Latina jurors. The trial court adopted the prosecution’s rationale, found that Juror 1 was confused about intent, and overruled the objection.The Superior Court of San Diego County presided over the trial and issued the challenged judgment, sentencing the defendant to a lengthy prison term. The defendant appealed, asserting that the trial court’s finding about Juror 1’s confusion was unsupported by the record. On appeal, the prosecution argued that the trial court’s factual finding was supported by substantial evidence and that the defendant had forfeited certain arguments for not making more specific objections during trial.The California Court of Appeal, Fourth Appellate District, Division One, reviewed the case. Applying de novo review as mandated by statute, the appellate court concluded that the record did not support the trial court’s finding that Juror 1 was confused about intent. The court further held that the prosecutor’s justification—juror confusion—was a presumptively invalid reason for a peremptory challenge under section 231.7 of the Code of Civil Procedure, and that the trial court failed to properly confirm the asserted behavior occurred. Because there was no substantial evidence to support the prosecutor’s stated reason, the appellate court held that the judgment must be reversed and remanded for a new trial. View "People v. Aguilar" on Justia Law