Justia Criminal Law Opinion Summaries

The case concerns a defendant who pleaded guilty to the premeditated murders of his mother and stepfather. In December 2021, he forced entry into their home, using a stolen firearm to shoot his mother six times and his stepfather four times. The defendant did not contest his responsibility for the crimes. Prior to sentencing, he presented evidence of severe mental illness, a troubled upbringing, and his acceptance of responsibility, seeking more lenient sentences based on these mitigating factors.The Bourbon District Court considered the defendant’s request for concurrent “hard 25” sentences, supported by expert testimony regarding his mental health and background. However, the court found that, while there were mitigating circumstances, they did not rise to the level of “substantial and compelling reasons” required to depart from the statutory “hard 50” sentence for premeditated first-degree murder. The court imposed two consecutive hard 50 sentences, emphasizing the brutal and premeditated nature of the crimes and the impact on the victims’ family. The defendant appealed directly to the Supreme Court of the State of Kansas, arguing that the district court abused its discretion in both the length and the consecutive nature of the sentences.The Supreme Court of the State of Kansas reviewed both sentencing decisions for abuse of discretion. The court held that the district court acted within its lawful discretion in declining to depart from the hard 50 sentences and in ordering the sentences to run consecutively. The court found that the mitigating evidence did not compel a lesser sentence given the facts of the case, and that the decision to impose consecutive sentences was reasonable in light of the gravity of the offenses. The defendant’s sentences were affirmed. View "State v. Mitchell " on Justia Law

Dennis O. Haynes III, serving a life sentence for first-degree murder, filed a motion requesting access to the warrants and their supporting materials in his criminal case. The district court granted him partial relief, allowing access to his arrest warrant and supporting affidavit but denying access to any search-warrant materials.Haynes initially pleaded guilty to multiple charges, including first-degree murder, in 2014 and was sentenced to life imprisonment without parole for 20 years. Nine years later, he filed a habeas corpus motion alleging ineffective assistance of counsel, which was refiled as a separate civil case. Subsequently, Haynes filed a postconviction motion in his criminal case requesting the probable-cause affidavits and all warrants. The district court denied this motion, but upon reconsideration, granted access to the arrest-warrant affidavit while denying access to search-warrant materials.The Kansas Supreme Court reviewed the case and found that K.S.A. 22-2302(b) and K.S.A. 22-2502(d) grant defendants a personal right to access affidavits or sworn testimony supporting arrest and search warrants, respectively, but do not address access to the warrants themselves. The court affirmed the district court's order granting Haynes access to the arrest-warrant affidavit but reversed the order denying access to search-warrant affidavits. The case was remanded with instructions to produce any search-warrant affidavits upon receipt of the necessary fee for production. View "State v. Haynes " on Justia Law

A three-year-old child, C.V., died in February 2019 while in the care of his mother’s domestic partner, Uraquio Arredondo, in Ulysses, Kansas. On the day of the incident, C.V. was behaving normally until left alone with Arredondo. Later that day, Arredondo called 911, reporting that C.V. had been in an accident. Emergency responders found C.V. unresponsive with extensive bruising. Medical examinations revealed that C.V. died from multiple blunt force injuries, including a fresh skull fracture and internal bleeding, with evidence of both recent and older injuries. Testimony from the daycare provider and C.V.’s father indicated prior signs of abuse, with C.V. attributing some injuries to Arredondo.The State charged Arredondo with felony murder and child abuse. He waived his right to a jury trial, and the Grant District Court judge found him guilty on both counts, imposing a life sentence for murder and a consecutive sentence for child abuse. During the investigation, law enforcement entered Arredondo’s residence three times without a warrant. Arredondo challenged the admissibility of evidence from the second and third entries, arguing lack of valid consent and coercion. He also sought to suppress his statements to law enforcement, claiming they were involuntary and made without Miranda warnings, but he had not objected to their admission at trial.The Supreme Court of the State of Kansas reviewed the case. It held that the second and third entries into the residence were lawful because Arredondo voluntarily consented to both searches, and the police lawfully secured the home based on probable cause. The court also found that Arredondo failed to preserve his challenge to the admissibility of his statements for appellate review. Finding no error, the court affirmed Arredondo’s convictions. View "State v. Arredondo " on Justia Law

Brian Beck was driving on Interstate 70 when a Geary County sheriff's deputy noticed that a frame around Beck's license plate partially obstructed the state name. The deputy executed a traffic stop, during which Beck appeared nervous and provided an odd explanation for his travel route. The deputy called for canine support, and the dog alerted to the presence of drugs. Beck consented to a search, and deputies found methamphetamine in his car. Beck was charged with possession of methamphetamine with intent to distribute, possessing a controlled substance without a drug tax stamp, and interference with law enforcement.The Geary District Court denied Beck's motion to suppress the evidence obtained from the search, ruling that the partial obstruction of the state name on the license plate justified the traffic stop. Beck was found guilty on all counts by a jury. The Kansas Court of Appeals affirmed the district court's decision, agreeing that the partial obstruction of the state name constituted a violation of Kansas law, thus justifying the stop.The Kansas Supreme Court reviewed the case and reversed the lower courts' decisions. The court held that Kansas law does not require the state name on a license plate to be clearly legible, only the alphanumeric display and registration decal. Therefore, the partial obstruction of the state name did not provide reasonable suspicion for the traffic stop. The court reversed Beck's convictions based on the evidence obtained during the search and remanded the case to the district court for a new hearing to determine if there were other valid grounds for the stop and seizure. View "State v. Beck " on Justia Law

In 2021, a jury convicted an individual of gross sexual imposition involving his 13-year-old cousin, resulting in her pregnancy. DNA evidence established a high probability that he was the father. During the trial, the prosecutor asked an improper question regarding family support for the victim and defendant, which led to a defense objection and a curative instruction from the judge. The defendant moved for a mistrial, which was denied. On direct appeal, the North Dakota Supreme Court found the improper question was not sufficiently prejudicial to warrant a new trial, as the jury was instructed to disregard it.Subsequently, the defendant filed a petition for postconviction relief in the District Court of Cass County, later amending it to argue that three recent North Dakota Supreme Court decisions involving the same prosecutor constituted newly discovered evidence of a pattern of prosecutorial misconduct. The district court analyzed the claim under the standard for newly discovered evidence, finding that while the cited cases were decided after the defendant’s trial, they were not material to the issues at trial and would not likely result in an acquittal. The court also held that the claim was barred by res judicata, as the issue of prosecutorial misconduct had already been fully litigated and decided on direct appeal.The North Dakota Supreme Court reviewed the district court’s denial of postconviction relief. It held that the recent decisions did not constitute newly discovered evidence material to the trial’s issues and would not likely result in an acquittal. The court further concluded that the claim was barred by res judicata because it had been fully and finally determined on direct appeal. The Supreme Court affirmed the district court’s judgment denying postconviction relief. View "Bazile v. State" on Justia Law

In 2009, Ciro Gomez was charged and found guilty of continuous sexual abuse of a child. His conviction was affirmed on appeal. In September 2024, Gomez filed a petition for postconviction relief, claiming a significant change in law and newly discovered evidence proving his innocence. The State moved for summary disposition, and the district court dismissed Gomez’s petition but later granted reconsideration. In January 2025, the court summarily dismissed the petition as untimely without an evidentiary hearing. Gomez appealed.The district court ruled that there had been no substantive change in the law applicable to Gomez’s case. Gomez had relied on State v. Noble, but the court found that Noble did not represent a significant change in the law. The court also determined that the alleged newly discovered evidence was not new, as it was known to Gomez at the time of his trial or discovered more than two years before filing the petition.The North Dakota Supreme Court reviewed the case and affirmed the district court’s decision. The court held that Gomez’s petition was untimely and did not meet the exceptions to the two-year filing rule under N.D.C.C. § 29-32.1-01(3). The court found that the evidence Gomez presented was not newly discovered and that any new information was known to him three years prior, exceeding the two-year limit for filing a postconviction relief application. Therefore, the district court did not err in summarily dismissing Gomez’s petition. View "Gomez v. State" on Justia Law

In 1996, when Riley was sixteen, he and two older teenagers drove around the District of Columbia looking for members of a rival group and ended up shooting and killing two young brothers. A few weeks earlier, Riley and the same teenagers had committed a similar crime in Maryland, resulting in another death. Riley pled guilty to first-degree murder in Maryland and was sentenced to life in prison. In D.C., a jury convicted him of two counts of first-degree murder while armed, assault with intent to kill while armed, and possession of a firearm during a crime of violence. He received sentences totaling seventy years to life, consecutive to his Maryland sentence.Riley's convictions were affirmed on direct appeal. In 2022, he filed a motion under the Incarceration Reduction Amendment Act (IRAA) seeking immediate release, arguing his rehabilitation and readiness to reenter society. The government did not oppose a sentence reduction but suggested a term of twelve years to life. The trial court held an evidentiary hearing and partially granted Riley's motion, reducing his sentence to time served plus three years and three months, relying on factors from the District’s determinate sentencing statute and voluntary sentencing guidelines.The District of Columbia Court of Appeals reviewed the case and found that the trial court erred by relying on non-IRAA statutes and factors, contrary to the recent decision in Doe v. United States. The court held that IRAA’s enumerated factors should exclusively guide the dangerousness and interests of justice inquiries. Consequently, the appellate court vacated the trial court’s decision and remanded for further proceedings consistent with IRAA’s statutory framework and the Doe decision. View "Riley v. United States" on Justia Law

The Wisconsin Department of Corrections (DOC) sought to revoke Keyo Sellers's probation based on five alleged violations, including entering K.A.B.'s home without consent, sexual assault, theft, trespassing, and providing false information to his probation agent. Sellers admitted to the fifth violation, and a revocation hearing was held for the remaining allegations. The DOC did not present K.A.B. as a witness, relying instead on her written statement and the testimony of a police officer. The Administrative Law Judge (ALJ) found the allegations substantiated and revoked Sellers's probation.Sellers appealed to the Division of Hearings and Appeals (DHA) administrator, who reversed the ALJ's decision, citing the reliance on hearsay evidence without good cause to deny Sellers's right to confront adverse witnesses. The administrator found that without K.A.B.'s testimony, there was insufficient evidence to support the revocation. The Milwaukee County Circuit Court reversed the administrator's decision, but the Court of Appeals reinstated it, agreeing that the administrator's decision was supported by substantial evidence and made according to law.The Wisconsin Supreme Court reviewed the case and upheld the Court of Appeals' decision. The court concluded that the administrator's decision was supported by substantial evidence, as the non-hearsay evidence presented was not compelling enough to establish the violations. The court also determined that the administrator correctly applied the law by excluding hearsay testimony without a finding of good cause. The decision to not revoke Sellers's probation was affirmed. View "Department of Corrections v. Hayes" on Justia Law

The State of Nebraska charged Paul Douglas Brooks with two counts of first-degree sexual assault and one count of third-degree sexual assault of a child, all involving the same victim, H.S. Brooks filed a plea in abatement, which was overruled, and he was arraigned. The State later filed a notice of intent to offer evidence of other sexual assaults by Brooks under Neb. Rev. Stat. § 27-414, identifying additional victims. Brooks requested time to take depositions of these witnesses, which delayed the hearing on the State’s notice.The district court for Furnas County overruled Brooks’ motion for absolute discharge based on statutory speedy trial grounds. Brooks conceded that the time related to his plea in abatement was excludable but argued that no other periods should be excluded. The court rejected the State’s argument that the period from arraignment to the status hearing should be excluded but agreed that the time Brooks requested to take depositions was excludable. The court found that Brooks’ request for time to take depositions constituted good cause under § 29-1207(4)(f) and excluded the period from May 23, 2024, to mid-July 2024, extending the trial deadline to October 26, 2024.The Nebraska Supreme Court reviewed the district court’s findings and affirmed the decision. The court agreed that the period from May 23 to mid-July was excludable for good cause, as Brooks requested this time to complete depositions. This exclusion extended the trial deadline beyond the date Brooks filed his motion for absolute discharge and the scheduled trial date. Therefore, the district court did not err in overruling Brooks’ motion for absolute discharge. View "State v. Brooks" on Justia Law

The defendant endured years of physical, emotional, and sexual abuse by her husband. On the night in question, after a violent attack in which her husband threatened her and chased her with a heavy object, she fled their home by car, despite having consumed alcohol earlier. She intended to reach the couple’s lake house, which she considered a safe place. While en route, she passed a police car but did not stop, later explaining that she distrusted the police due to prior negative experiences. She was stopped by police before reaching her destination and was found to have a blood alcohol concentration above the legal limit. She was charged with operating a motor vehicle with a prohibited alcohol concentration as a second offense.The Waukesha County Circuit Court conducted a bench trial. The defendant stipulated to her blood alcohol level but raised the statutory coercion defense, arguing that she reasonably believed driving was the only way to prevent imminent death or great bodily harm. The circuit court found that the defense applied when she initially fled but concluded that, by the time she passed the police car, she knew other means of safety were available and thus the elements of the defense were no longer met. The court found her guilty. The Wisconsin Court of Appeals affirmed, emphasizing the circuit court’s finding that her belief in the necessity of continued driving was no longer reasonable once she was out of immediate danger and had other options.The Supreme Court of Wisconsin reviewed the case. It held that the elements of the coercion defense must be met throughout the entire duration of an ongoing, otherwise-criminal act, not just at its inception. The court also held that a defendant’s personal history can be relevant to the reasonableness of her belief in the necessity of her actions. Finding that the circuit court applied the correct legal standards and that its decision was supported by sufficient evidence, the Supreme Court affirmed the decision of the court of appeals. View "State v. Stetzer" on Justia Law