Justia Criminal Law Opinion Summaries

The case involves Joseph C. Boeggeman, who was convicted in Nebraska for two counts of attempted first degree sexual assault and one count of attempted third degree sexual assault. During the Nebraska criminal proceedings, Boeggeman was serving an unrelated sentence in Massachusetts. After his sentencing hearing in Nebraska in February 2017, and before the time for filing an appeal had expired, Boeggeman was returned to Massachusetts, where he remained until January 2020.Boeggeman filed a motion for postconviction relief in December 2020, arguing that there was a discrepancy between the trial court's pronounced sentence and its written sentencing order regarding whether his Nebraska sentences were to run concurrently with or consecutively to his Massachusetts sentence. The district court denied his motion without an evidentiary hearing, concluding that his motion was untimely and that equitable tolling did not apply to the 1-year limitation of § 29-3001(4).The Nebraska Supreme Court affirmed the district court's decision. The court held that the 1-year limitation period for filing a postconviction motion under § 29-3001(4) is not subject to equitable tolling. The court also noted that postconviction relief is only available where a constitutional violation renders the judgment void or voidable, and Boeggeman's supplemental allegations, which all occurred after his judgment was entered, had no bearing on the underlying judgment. View "State v. Boeggeman" on Justia Law

The Nebraska Supreme Court affirmed the convictions and sentences of Bailey M. Boswell for premeditated first degree murder, conspiracy to commit first degree murder, and improper disposal of human skeletal remains. Boswell and her co-conspirator, Aubrey C. Trail, were charged after the dismembered remains of 24-year-old Sydney Loofe were discovered. The court found no error in the district court's evidentiary rulings, which included the admission of photographs of Loofe's dismembered body, evidence of sex toys, sexual fantasies, and sexual torture, testimony about witchcraft and the occult, and hearsay statements by Trail under the coconspirator exemption to the hearsay rule. The court held that the evidence was relevant and admissible under Nebraska law, and that its probative value was not substantially outweighed by the danger of unfair prejudice. The court also found that the State had sufficiently proved the existence of a conspiracy through independent evidence, allowing for the admission of Trail's statements under the coconspirator exception to the hearsay rule. View "State v. Boswell" on Justia Law

The defendant, Warren W. Dunn, was charged with two counts of possession of child pornography and two counts of possession of child pornography as a subsequent offense. The charges were based on evidence found in his apartment during a search conducted under a warrant. The warrant was issued based on an affidavit by a state trooper, who had received a report from the National Center for Missing and Exploited Children (NCMEC) about two images flagged as potential child pornography by Microsoft. The trooper described the images in his affidavit but did not attach them. The defendant had previously been arrested in 2007 for possession of child pornography.In the Superior Court, the defendant filed motions to suppress the evidence and for a hearing on the affidavit supporting the search warrant. The court denied both motions. The defendant then pleaded guilty to all charges, preserving his right to appeal the denials of his motions.The Supreme Judicial Court of Massachusetts affirmed the lower court's decisions. The court held that, although attaching the photographs or providing a more detailed description would have been preferable, the affidavit as a whole was sufficient to establish probable cause for the search warrant. The court also held that the motion judge did not abuse her discretion in concluding that the defendant failed to demonstrate that the trooper's descriptions of the images were false. The court declined to create a new rule requiring magistrates to personally view allegedly lewd images before issuing search warrants. View "Commonwealth v. Dunn" on Justia Law

John Garon Saxton was convicted of aggravated assault for hitting his father-in-law, Toby Melton, in the head with a metal bat. The incident occurred after an altercation between Saxton and his mother-in-law, Vickie Melton, over Saxton disciplining his son. Saxton claimed he slapped Vickie after she pushed him near his injured shoulder, which Vickie denied. Vickie called Toby, but did not tell him about the slap. Saxton testified that he heard Vickie tell Toby about the slap over the phone. When Toby arrived, Saxton told him about the slap, and Toby reacted by pushing Saxton away. Saxton then retrieved a gun from his car, but did not point it at Toby. Saxton claimed that Toby then approached him again, prompting him to grab a bat and hit Toby.The trial court granted two jury instructions submitted by the State and denied a jury instruction submitted by the defense. Saxton appealed, arguing that the trial court erred in its decisions regarding the jury instructions.The Supreme Court of Mississippi affirmed the lower court's decision. The court found no reversible error with the trial court’s rulings on the jury instructions. The court held that while one of the State's instructions was an incomplete statement of Mississippi law, it did not result in a manifest miscarriage of justice, particularly given that Saxton was granted a self-defense instruction. The court also found no merit in Saxton's claim that the trial court erred by denying his proposed instruction, as the content of that instruction was covered elsewhere in the instructions. View "Saxton v. State" on Justia Law

In 2000, Antonio McDowell, a juvenile at the time, was convicted of capital murder and sentenced to life without parole. Following a 2012 Supreme Court ruling in Miller v. Alabama, which deemed mandatory life sentences without parole for juvenile defendants unconstitutional, McDowell's sentence was vacated. The trial court then proceeded with a jury trial for sentencing under Mississippi Code Section 99-19-101. The jury, after considering evidence related to the Miller criteria, was unable to agree on a sentence. The trial judge, instead of imposing a sentence of life, sentenced McDowell to life without parole, a decision that was affirmed by the Court of Appeals.The Mississippi Supreme Court, on certiorari review, found that the trial court's decision to proceed with a jury trial for sentencing under Section 99-19-101 made the section applicable to the entirety of the proceedings. This applicability continued when the jury failed to agree on a sentence. Therefore, the trial court erred by conducting the Miller analysis and sentencing McDowell to life without parole. The Supreme Court reversed the judgments of the Court of Appeals and the trial court and remanded the case back to the trial court for proceedings consistent with its opinion. View "McDowell v. State" on Justia Law

The case involves Miguel F. Ramirez-Ayala, who pleaded guilty to illegal possession of firearms and controlled substances in 2015. After serving his federal prison sentence, he began a three-year supervised-release term. However, within a year, Ramirez-Ayala violated his supervised-release conditions by possessing controlled substances and a firearm, among other violations. This led to a revocation sentence of eighteen months, after which he began another supervised-release term. During this second term, Ramirez-Ayala committed multiple violations, including drug and firearm possession, and evaded police in a high-speed car chase. In 2021, he pleaded guilty to these most recent drug and firearm possession charges, leading to another round of revocation proceedings.The district court sentenced Ramirez-Ayala to twenty-four months' imprisonment, the maximum revocation sentence, to be served consecutively to his new conviction. He appealed, arguing that the district court sentenced him in a procedurally and substantively unreasonable manner.The United States Court of Appeals for the First Circuit found no error in the district court's decision. The court noted that the district court had considered the relevant factors, including the seriousness of Ramirez-Ayala's violations, his repeated violations of supervised-release conditions, and his disregard for the law and public safety. The court concluded that the district court's upward variance in sentencing was reasonable given these circumstances. Therefore, the court affirmed the district court's decision. View "US v. Ramirez-Ayala" on Justia Law

The case involves Jesse Calvin Gilbert, who was pulled over by a law enforcement deputy due to a non-operating license plate light. Gilbert was arrested on an active warrant, and the deputy conducted a warrantless search of the vehicle. During the search, the deputy found a handgun under the driver's seat. Gilbert, an ex-felon, was charged with possession of a firearm and moved to suppress the evidence, arguing that the search was not a true inventory search but a ruse to conduct an investigatory search.The district court denied Gilbert's motion, finding that the deputy appropriately impounded the vehicle and the inventory search was reasonable. Gilbert appealed his subsequent conviction based on the search and the unsuppressed evidence.The Supreme Court of Nevada affirmed the district court's decision. The court clarified that an investigatory motive does not necessarily invalidate an inventory search as long as the search that occurred is the same as the inventory-based search that would have happened absent any such motivation. The court also stated that a court deciding a suppression motion must determine the search's reasonableness under the totality of the circumstances by evaluating the extent to which law enforcement departed from the standardized procedures, whether the scope of the search was as expected in light of the underlying justifications for inventory searches, and whether the inventory produced served the purposes of an inventory search. The court concluded that the search was reasonable and denied Gilbert's motion to suppress. View "GILBERT VS. STATE" on Justia Law

The case involves Steven Duarte, who was convicted for violating 18 U.S.C. § 922(g)(1), a law that prohibits anyone previously convicted of a crime punishable by imprisonment for over a year from possessing a firearm. Duarte, who had five prior non-violent state criminal convictions, was charged and convicted under this law after police saw him discard a handgun from a moving car.Duarte appealed his conviction, arguing that § 922(g)(1) violated his Second Amendment rights. The United States Court of Appeals for the Ninth Circuit agreed with Duarte, finding that the law was unconstitutional as applied to him, a non-violent offender who had served his time in prison and reentered society. The court held that under the Supreme Court's decision in New York State Rifle & Pistol Ass'n v. Bruen, § 922(g)(1) violated the Second Amendment as applied to Duarte. The court concluded that Duarte's weapon, a handgun, is an "arm" within the meaning of the Second Amendment, and that the government failed to prove that § 922(g)(1)'s categorical prohibition, as applied to Duarte, is part of the historic tradition that delimits the outer bounds of the Second Amendment right. As a result, the court vacated Duarte's conviction and reversed the district court's judgment. View "USA V. DUARTE" on Justia Law

The case involves a defendant who was found guilty of driving under the influence of intoxicants. After his conviction, the defendant fled the state, delaying his sentencing and the entry of a judgment of conviction for over ten years. Upon his return to Oregon, the trial court imposed a sentence and entered a judgment of conviction, which the defendant appealed. The defendant argued that the trial court erred by failing to caution the jury that a defendant’s decision not to testify cannot be considered evidence of guilt.The Court of Appeals dismissed the defendant's appeal based on the "former fugitive doctrine," which presumes that an appellate court has inherent authority to dismiss a criminal defendant’s direct appeal if the defendant was formerly a fugitive from justice and the flight significantly interfered with the appellate process. The state argued that the defendant's decade-long absence would prejudice the state in any retrial due to the passage of time and difficulty in locating witnesses.The Supreme Court of the State of Oregon reversed the decision of the Court of Appeals. The Supreme Court held that while the Court of Appeals may have inherent authority to dismiss an appeal when the defendant's former fugitive status significantly interferes with the appellate process, this authority does not extend to dismissing a direct appeal to address the appellant’s flight from the jurisdiction of the trial court. The Supreme Court concluded that the defendant's former fugitive status did not interfere with the appellate court’s ability to address the merits of the appeal. The court held that concerns about potential prejudice that would arise in the trial court in relation to a retrial are most appropriately left for the trial court to address on any remand. View "State v. Satter" on Justia Law

The case involves James Joseph Lanpher, Jr., who pleaded guilty to two counts of aggravated assault against a law enforcement officer and admitted to being a habitual offender. The charges stemmed from a dangerous high-speed chase during which Lanpher repeatedly fired weapons at pursuing officers. The circuit court sentenced Lanpher to serve two concurrent life sentences to run consecutively to sentences he was already serving for other offenses. Lanpher appealed, claiming his sentence was cruel and unusual in violation of the Eighth Amendment and was an abuse of the circuit court’s discretion.The case was previously reviewed by the circuit court of the Third Judicial Circuit, Lake County, South Dakota. The court found Lanpher guilty and sentenced him to two concurrent life sentences, to be served consecutively to sentences he was already serving for other offenses.The Supreme Court of the State of South Dakota reviewed the case and affirmed the decision of the lower court. The court found that Lanpher's sentence did not constitute cruel and unusual punishment in violation of the Eighth Amendment. The court also found that the circuit court did not abuse its discretion in the imposition of Lanpher’s sentence. The court noted that Lanpher's violent criminal history and demonstrated disregard for human life justified the severity of his sentence. View "State v. Lanpher" on Justia Law