Justia Criminal Law Opinion Summaries

The defendant pleaded guilty to one count of sexual misconduct, a conviction that triggers registration requirements under the Sex Offender Registration Act (SORA). At the time of his plea, he was not notified of these obligations, and neither the Board of Examiners of Sex Offenders nor the sentencing court took the steps required by statute to initiate SORA registration. Approximately five years passed before the Board became aware of his conviction. During this period, the defendant remained unregistered and worked at a facility for juveniles. Once the oversight was discovered, a full SORA proceeding was conducted, resulting in his classification as a level one sex offender, which carries the least restrictive requirements and a twenty-year registration period ordered nunc pro tunc from the date of his release.After the SORA hearing, the defendant moved to dismiss the proceedings, arguing that the delay violated his substantive due process rights, and alternatively sought to be designated an unclassified offender. The Supreme Court denied these requests but reduced his risk level from two to one after declining to assess points for release without supervision based on his conduct during the delay. The Appellate Division affirmed, noting that the delay did not prejudice the defendant and, in fact, benefited him by lowering his risk level.The New York Court of Appeals reviewed the case and held that a defendant must demonstrate prejudice to his ability to present his case at the SORA hearing to establish a substantive due process violation for delayed proceedings. Because the defendant did not suffer prejudice—instead, he received a less onerous classification due to the delay—the Court of Appeals concluded that the delay did not violate his substantive due process rights and affirmed the order of the Appellate Division. View "People v Collier" on Justia Law

Tony Lee Johnson, a convicted felon on supervised release, was arrested by law enforcement officers after he violated his release conditions by failing drug tests. The arrest was executed at Johnson’s residence when he and his girlfriend, Beatrice Simmons, were found in his vehicle. After Johnson was removed and arrested, Simmons was temporarily detained but not handcuffed. Officer Pringle, suspecting Johnson might be hiding something, conducted a warrantless search of the vehicle's driver area and center console, discovering a loaded handgun. Simmons stated she was unaware of the firearm and confirmed she was on parole for a prior drug offense.The United States District Court for the Northern District of Texas held a hearing on Johnson’s motion to suppress the handgun, which he argued was seized in violation of his Fourth Amendment rights. The district court denied the motion, finding the search constitutional under the protective-sweep exception outlined in Michigan v. Long, reasoning that Simmons posed a potential threat to officer safety due to her criminal history, relationship with Johnson, and emotional proximity to the arrest. Johnson then entered a conditional guilty plea, reserving his right to appeal the denial of the suppression motion, which led to his appeal to the Fifth Circuit.The United States Court of Appeals for the Fifth Circuit reviewed the district court’s factual findings for clear error and legal conclusions de novo. The Fifth Circuit held that the warrantless search was not justified under the protective-sweep exception because no specific, articulable, contemporaneous facts suggested Simmons was potentially dangerous or would access a weapon. The court reversed the district court’s denial of the suppression motion and vacated Johnson’s conviction and sentence. View "United States v. Johnson" on Justia Law

Three brothers accused their stepfather of emotional, physical, and sexual abuse that occurred over several years when they were minors. The allegations included sadistic and lewd conduct, with all three boys describing similar patterns of abuse and threats. After Child 1 disclosed abuse to his mother, Child 3 and Child 2 also reported similar mistreatment. The stepfather was charged with three counts of lewd conduct with minors under sixteen, each count corresponding to one of the brothers.After a preliminary hearing in the Magistrate Court, the defendant was bound over to the District Court for trial on all three counts, despite one count being temporarily remanded for additional findings. At trial in the District Court of the Sixth Judicial District, Bannock County, each of the boys testified. The State introduced text messages between Child 2 and his mother to rebut the defense’s theory of fabrication. The defense objected to these messages as hearsay, irrelevant, and as containing evidence of uncharged bad acts. The court admitted the messages with a limiting instruction and also permitted a forensic interviewer to provide testimony that touched on expert opinion, despite being disclosed only as a fact witness. During trial, a juror disclosed she had attended middle school with one of the victims, but the court, after inquiry, declined to remove her for cause. The jury convicted the defendant on two counts relating to the older children and acquitted him regarding Child 1. The defendant was sentenced to two concurrent life sentences with fixed terms, later reduced from 25 to 20 years on a Rule 35 motion.The Idaho Supreme Court reviewed four alleged errors: denial of the juror’s removal, admission of the text messages, permitting the forensic interviewer’s testimony, and the sentence’s excessiveness. The Court held that the District Court did not abuse its discretion regarding juror removal, the text messages were properly admitted for a non-hearsay purpose (though references to physical abuse should have been redacted, the error was harmless), and any error in the forensic interviewer’s testimony was likewise harmless. The sentence imposed was affirmed as within the court’s discretion. The judgment and sentence were affirmed. View "State v. Frandsen" on Justia Law

Marcus Mello was charged with multiple offenses in connection with drug trafficking activities in Maine, including distributing pills purported to be oxycodone but containing fentanyl, possession with intent to distribute fentanyl, possession of a firearm in furtherance of drug trafficking, and later, failing to appear for his scheduled jury trial. The investigation linked Mello to a supplier named "Chop" and documented several large shipments of pills, some of which were sold to individuals, one of whom subsequently died from fentanyl toxicity. Law enforcement seized thousands of pills, a firearm, and cash during Mello’s arrest, and communications confirmed ongoing drug transactions over several months.Following his indictment in the United States District Court for the District of Maine, Mello pleaded guilty to all charges. At sentencing, the district court calculated a Guidelines range of 228-270 months, based on drug quantity, criminal history (including juvenile adjudications), and enhancements for obstruction of justice due to his failure to appear. The court denied Mello’s requests for downward departures related to age, mental health, and overrepresentation of criminal history, and also denied a reduction for acceptance of responsibility. After considering the factors under 18 U.S.C. § 3553(a), the court varied downward and sentenced Mello to a total of 181 months’ imprisonment.On appeal to the United States Court of Appeals for the First Circuit, Mello challenged his sentence on both procedural and substantive grounds. The First Circuit reviewed the district court’s factual findings and legal conclusions for clear error and abuse of discretion, and procedural rulings de novo. The appellate court held that the district court had not erred in its drug quantity calculation, consideration of juvenile adjudications, application of enhancements and denials of reductions, or its refusal to depart further from the Guidelines. The First Circuit concluded that the sentence was both procedurally and substantively reasonable and affirmed the district court’s judgment. View "United States v. Mello" on Justia Law

Marilyn Besosa-Noceda moved from Puerto Rico to Texas with her daughter, whose biological father, Emmanuel Santiago-Melendez, objected to the relocation and subsequently filed criminal charges against Besosa, alleging she deprived him of access to his child. Santiago’s complaint led to Besosa’s arrest in Texas and extradition to Puerto Rico. Ultimately, the criminal charges were dismissed after Besosa demonstrated a lack of probable cause.After the dismissal, Besosa filed suit in the United States District Court for the District of Puerto Rico against the police officer who received Santiago’s complaint, the prosecutor who authorized the criminal charges, and the prosecutor’s supervisor. She alleged malicious prosecution under 42 U.S.C. § 1983 and Commonwealth law, claiming her constitutional rights were violated by the initiation of legal process unsupported by probable cause. The defendants moved for summary judgment, which the district court granted. The court found the arrest warrant was issued by a judge based on probable cause and was not obtained through false statements or omissions. The district court also rejected Besosa’s claim that her absence from the probable cause hearings violated her rights, finding no entitlement under Commonwealth law to be present at such hearings.On appeal, the United States Court of Appeals for the First Circuit reviewed Besosa’s arguments, including a challenge to an unresolved discovery dispute and the merits of the summary judgment ruling. The First Circuit held that Besosa failed to invoke the proper procedural mechanism to delay summary judgment pending discovery and that she did not present evidence showing the defendants knowingly provided false information or recklessly disregarded the truth when seeking the arrest warrant. The First Circuit affirmed the district court’s grant of summary judgment for the defendants. View "Besosa-Noceda v. Capo-Rivera" on Justia Law

On the evening of Black Friday in 2021, two employees at a T-Mobile store in Columbus, Ohio were robbed at gunpoint by a masked individual who forced them into a back room, demanded phones and money, and sprayed them with mace before fleeing. Unbeknownst to the robber, a bait phone with a GPS tracker was included among the stolen items, allowing police to quickly locate and apprehend him after a high-speed chase. The suspect, Kevin Daniels, was arrested and, after waiving his Miranda rights during interrogation, admitted to the crime. A search of his vehicle found the stolen goods, a gun, and the disguise used in the robbery.The United States District Court for the Southern District of Ohio presided over Daniels’s trial. He was indicted on three counts: Hobbs Act robbery, brandishing a firearm during a crime of violence, and felon-in-possession of a firearm. After a jury convicted him on all counts, the district court calculated a sentencing guidelines range of 78 to 97 months for the robbery and possession offenses, and imposed the mandatory minimum 7-year sentence for the firearm offense, resulting in a total sentence of 181 months. Daniels raised various pretrial and sentencing challenges, including suppression of statements, issues with counsel, discovery violations, and objections to guideline enhancements.The United States Court of Appeals for the Sixth Circuit reviewed Daniels’s appeal, which included constitutional, evidentiary, instructional, and sentencing claims. The court held that Daniels knowingly and voluntarily waived his Miranda rights, that the district court did not abuse its discretion in denying substitution of counsel, and that there was no reversible error related to discovery or jury instructions. The court also affirmed the application of the physical-restraint and bodily-injury enhancements, and found no error in the calculation of Daniels’s criminal history score. The judgment of the district court was affirmed. View "United States v. Daniels" on Justia Law

Two plainclothes detectives in Baltimore, acting on a tip about drug activity, observed Robert Gary Moore and another individual near a parked vehicle. When approached, Moore dropped a plastic bag and fled but was apprehended. The police recovered the bag, which was later analyzed in a laboratory report stating it contained cocaine. During Moore’s trial for possession and possession with intent to distribute, the State introduced two chain-of-custody reports: one disclosed before trial and another (the ECU report) disclosed only mid-trial. The latter did not mention the chemist who performed the analysis, raising questions about whether the correct bag was tested. Moore’s counsel did not object to the late disclosure or use the discrepancy in his defense. Moore was convicted by a jury.After his conviction was affirmed on appeal by Maryland’s intermediate appellate court, Moore sought postconviction relief in Maryland state court, arguing that the State’s belated disclosure of the ECU report violated his due process rights under Brady v. Maryland and that his counsel was ineffective. The Maryland trial court initially granted relief under Brady but, upon remand from the intermediate appellate court for further factfinding, ultimately denied both claims, finding that disclosure during trial did not constitute suppression under Brady. Moore’s application for leave to appeal this denial was rejected.Moore then filed a federal habeas petition in the United States District Court for the District of Maryland. The district court found a Brady violation and granted habeas relief, ordering Moore’s conviction vacated unless retried within sixty days. On appeal, the United States Court of Appeals for the Fourth Circuit agreed that the state court had unreasonably applied federal law and that a Brady violation warranted habeas relief. However, it held that federal district courts lack authority to vacate state convictions directly and thus vacated the district court’s order, remanding for a new order consistent with the proper bounds of federal habeas relief. View "Moore v. State of Maryland" on Justia Law

Border Patrol agents observed a suspicious vehicle near the U.S.-Mexico border in Southern California. After the driver, Alex Ruiz, failed to stop for marked Border Patrol units, agents deployed spike strips and eventually apprehended him. Nearby, four individuals without legal immigration status were found hiding. Evidence at trial established that Ruiz transported these individuals, and a co-defendant testified to having coordinated the pickup with Ruiz.The United States District Court for the Southern District of California presided over Ruiz’s trial. The government introduced a prior conviction Ruiz had for transporting illegal aliens, redacting prejudicial details. Ruiz objected, arguing its admission was improper under Federal Rule of Evidence 404(b) and that it was unconstitutional. The district court admitted the prior conviction to show knowledge and lack of mistake, provided limiting instructions to the jury, and took further steps to minimize prejudice, such as not allowing the documents into the jury room during deliberations. The jury convicted Ruiz on all counts, and he was sentenced to thirty-three months in prison and three years of supervised release.On appeal, the United States Court of Appeals for the Ninth Circuit reviewed whether the district court abused its discretion in admitting evidence of Ruiz’s prior conviction under Rule 404(b) and whether its probative value was substantially outweighed by unfair prejudice under Rule 403. The court held the prior conviction was properly admitted to prove knowledge, was not too remote in time, was supported by sufficient evidence, and was sufficiently similar to the charged conduct. The appellate court also found that any prejudice did not substantially outweigh the conviction’s probative value and that Ruiz waived his constitutional arguments by not raising them below. The Ninth Circuit affirmed the district court’s judgment. View "USA V. RUIZ" on Justia Law

A group of individuals, including the appellant, participated in a scheme involving the use of stolen credit cards and fraudulent memberships at a warehouse store to purchase large quantities of cigarettes. The appellant served as the primary account holder for two business membership accounts and was a secondary member on two others. The scheme resulted in over $2 million in cigarette purchases. Following an 85-count indictment, the appellant was charged with conspiracy to commit credit card fraud, several counts of credit card fraud, and aggravated identity theft. After his codefendants pleaded guilty, the appellant proceeded to trial. During the trial, the government presented testimony from victims whose credit cards were used without authorization. The district court granted the appellant’s motion for acquittal on certain counts due to insufficient evidence, and the jury acquitted him on others, but found him guilty of the remaining charges.The United States District Court for the Northern District of Georgia sentenced the appellant, holding him accountable for the total loss amount charged by all members of the conspiracy using the shared credit cards. This figure was calculated in the presentence report and included losses attributable to the codefendants, except for those counts where the appellant was acquitted. The appellant objected, arguing that he should only be held responsible for transactions he personally conducted, but the district court overruled his objection and imposed restitution matching the total loss amount.On appeal, the United States Court of Appeals for the Eleventh Circuit concluded that the district court committed legal error by failing to make individualized findings regarding the scope of criminal activity undertaken by the appellant, as required under the Sentencing Guidelines. The appellate court vacated the appellant’s sentence and restitution order, remanding for resentencing with instructions to determine the loss amount based on the appellant’s own conduct and correct a clerical error in the judgment. View "USA v. Barry" on Justia Law

A 16-year-old individual was criminally charged in Montana with several offenses, including aggravated burglary and assault on a peace officer. The prosecution filed an Information in the District Court, and a hearing was scheduled to decide whether the matter should be transferred to Youth Court, as permitted by Montana law for certain juvenile defendants. Before being arraigned, the defendant moved to substitute the presiding judge, arguing the motion was timely since arraignment had not yet occurred.The Montana Fourth Judicial District Court, Missoula County, denied the substitution motion without prejudice, reasoning that such motions are prohibited in Youth Court actions and would only be considered if the case remained in District Court following the transfer hearing. The court also issued an order for evaluation to assist in the transfer determination, but the order was initially filed under an incorrect cause number. The defendant then petitioned the Montana Supreme Court for a writ of supervisory control, claiming the denial of the substitution motion was erroneous because the case was pending in District Court as a criminal action, not a Youth Court matter.The Supreme Court of the State of Montana reviewed the case. It held that after the State files an Information in District Court, jurisdiction over the criminal matter rests with the District Court, and the action is not a Youth Court case at that stage. The court further clarified that under Montana law, a defendant’s right to substitute a judge in criminal cases may be exercised any time before arraignment, and that the 10-day window for substitution closes at arraignment rather than opening at that point. The Supreme Court granted the petition for supervisory control, set aside the District Court’s order denying substitution, and remanded for further proceedings consistent with its opinion. View "S.L. v. 4th Judicial District Court" on Justia Law