Justia Criminal Law Opinion Summaries

The case involves a fatal shooting that occurred after a drug transaction went awry. The appellant contacted the victim to purchase methamphetamine, but the victim, with the help of another party, gave him less than he paid for by mixing in filler material. The appellant later learned of this deception and expressed anger about being shorted, indicating that the money used was not his own. On the day of the shooting, the appellant was present at the victim’s residence for much of the day, and a series of interactions involving the appellant, the victim, and others occurred. Shortly before the shooting, the appellant learned definitively that the victim was responsible for the shorted drug deal. The victim was shot and died from her injuries. Evidence presented at trial included cell phone location data placing the appellant at the crime scene, gunshot residue on his clothing, and testimony regarding his motive and opportunity.A jury in the Superior Court of Newton County convicted the appellant of malice murder and related offenses. The trial court sentenced him to life imprisonment for malice murder and imposed a consecutive sentence for possession of a firearm during the commission of a felony. The appellant moved for a new trial, arguing, among other things, that the verdict was contrary to the evidence and that the trial court should exercise its discretion under the “general grounds.” The trial court denied the motion for new trial, focusing on the sufficiency of the evidence.The Supreme Court of Georgia reviewed the appeal. The Court held that the evidence was constitutionally sufficient to support the convictions when viewed in the light most favorable to the verdict. However, the Court found that the trial court failed to exercise its discretion under the general grounds in considering the motion for new trial. The Supreme Court affirmed the convictions in part, vacated the order denying the motion for new trial, and remanded the case for the trial court to exercise its discretion and issue an appropriate order. View "SMITH v. THE STATE" on Justia Law

Bobby Crawford was convicted after a jury trial for malice murder in the beating death of his roommate, Timothy Walker. The evidence established that Crawford, Walker, and a third roommate, Bobby Johnson, lived together. On the night in question, Johnson heard Crawford and Walker arguing, followed by sounds of a physical fight. Johnson saw Crawford beating Walker, including striking him with a firearm, for an extended period, despite Walker becoming incapacitated and unable to defend himself. Crawford later told Johnson that he thought he had killed Walker and instructed Johnson to lie to the police. The autopsy revealed severe blunt force injuries to Walker’s head and neck, resulting in death.Crawford was indicted by a Fulton County grand jury for malice murder, felony murder, and aggravated assault. At trial, the jury found him guilty on all counts. The Superior Court of Fulton County sentenced him to life without parole for malice murder, with the other counts merged or vacated. Crawford filed a motion for new trial, which was denied, then appealed.The Supreme Court of Georgia reviewed the case. It held that the evidence was constitutionally sufficient to support the conviction, as a rational jury could have rejected Crawford’s self-defense claim based on testimony and physical evidence. The Court found that even if it was error to admit evidence of a prior aggravated battery conviction, the error was harmless due to the overwhelming evidence of guilt. The Court also concluded that Crawford failed to show reversible error regarding the limitation of his cross-examination of Johnson about drug use, and that his motion for mistrial was not timely. Therefore, the Supreme Court of Georgia affirmed the judgment. View "CRAWFORD v. THE STATE" on Justia Law

An infant named Kobe, who suffered from a severe genetic disorder and was unable to move or feed himself without assistance, died in March 2016 in an apartment shared with his parents and maternal grandmother, Monroe. The night before his death, Kobe was given teething gel and mashed potatoes, and was later found unresponsive with signs of rigor mortis. An autopsy revealed methamphetamine in Kobe’s blood at levels consistent with direct administration, rather than secondary exposure. Witnesses testified that Monroe admitted to putting meth in Kobe’s mouth to calm him, and expert testimony linked the meth to Kobe’s death. After the incident, Monroe evaded police for a month, altered her appearance, and used false names.Monroe was indicted in the Superior Court of Fulton County for malice murder, felony murder, cruelty to children, and distribution of methamphetamine. Her first trial in May 2018 resulted in a hung jury. At her second trial in November 2022, a jury found her guilty on all charges. The court sentenced her to life imprisonment without parole for malice murder, with concurrent sentences for other convictions. Monroe’s motion for a new trial was denied by the Superior Court of Fulton County.On appeal to the Supreme Court of Georgia, Monroe argued that the evidence was constitutionally insufficient to support her convictions and that she received ineffective assistance of counsel. The Supreme Court of Georgia held that the evidence was sufficient for a rational jury to find Monroe guilty beyond a reasonable doubt, including on the grounds that “distribution” of meth did not require a sale but encompassed an intentional transfer. The court also concluded that Monroe’s counsel did not render ineffective assistance. Accordingly, the Supreme Court of Georgia affirmed the convictions. View "MONROE v. THE STATE" on Justia Law

The case arose from a drive-by shooting incident in Atlanta on April 7, 2016, which resulted in the death of James Simmons and injuries to Trevis Bufford. Evidence at trial showed that Deqaveon Malcolm and Jamon Freeman, both associated with the “Bird Gang” subset of the Bloods gang, engaged in a series of confrontations with Bufford and Simmons. After an altercation where Malcolm took possession of two guns, a retaliatory shooting occurred. Surveillance video, cell phone data, and ballistic evidence linked Malcolm and Freeman to the shooting, with further evidence connecting Malcolm’s mother’s car to the crime scene.A Fulton County jury convicted Malcolm of felony murder, aggravated assault, criminal street gang activity, and criminal damage to property, among other charges, in 2018. Malcolm was acquitted of other counts. He filed a motion for a new trial, which was denied by the Superior Court of Fulton County after an evidentiary hearing. Malcolm then appealed to the Supreme Court of Georgia, arguing that the evidence was constitutionally insufficient, his trial counsel was ineffective for not filing a motion to suppress evidence from his mother’s car, and the trial court erred by not removing a juror who failed to disclose her involvement as a crime victim in another case.The Supreme Court of Georgia held that the evidence presented at trial was sufficient for a rational juror to convict Malcolm beyond a reasonable doubt. The Court found that trial counsel’s decision not to pursue a motion to suppress was an objectively reasonable strategic choice, given conflicting evidence about Malcolm’s access to the car and potential prejudice. The Court also determined that the trial court did not abuse its discretion in retaining the juror, as there was no evidence of intentional misconduct or bias. The Supreme Court of Georgia affirmed the judgment. View "MALCOLM v. THE STATE" on Justia Law

A substitute teacher sexually assaulted a thirteen-year-old student on multiple occasions in a classroom, recorded at least two of the assaults, and shared one of the videos with adults in an online chatroom. The Federal Bureau of Investigation found child pornography on his phone and evidence of further distribution. The student confirmed multiple instances of abuse, which significantly impacted his mental health. The teacher was subsequently federally prosecuted and sentenced to seventeen and a half years for production of child pornography. In parallel state proceedings, he was indicted on several charges, pled guilty to three, and was sentenced to an aggregate thirty years in prison, with some terms ordered to run consecutively and concurrently.In the Circuit Court of the First Circuit, the court granted the State’s oral motion for consecutive sentences at sentencing but provided only a brief, generalized rationale focused on the teacher-student relationship and harm to the victim. It did not address the distinct nature of the offenses or provide a detailed explanation for departing from the presumptive concurrent sentencing. After the defendant appealed, the court issued a written order—drafted by the prosecution and adopted verbatim—offering a more comprehensive justification for the consecutive sentences. The Intermediate Court of Appeals (ICA) affirmed the sentence, relying heavily on this post-sentencing written order.The Supreme Court of the State of Hawai‘i vacated the ICA’s judgment and the portion of the circuit court’s sentence imposing consecutive terms. The court held that a sentencing court must state its reasons for imposing consecutive sentences on the record at the time of sentencing, not in a later written order, and must not simply adopt the prosecutor’s arguments. The case was remanded to the circuit court for resentencing. View "State v. Bunag" on Justia Law

A man was prosecuted after a person, J.R., died from a fentanyl overdose following the purchase of drugs from him. The central witness was J.R.’s girlfriend, who described the events leading up to J.R.’s death, including a meeting at a bank where J.R. met the defendant and returned with drugs packaged in foil. Video surveillance, financial records, and communications via Facebook Messenger corroborated the meeting and drug transaction. Law enforcement arrested the defendant during a sting operation using J.R.’s phone, and drugs found during the arrest matched the chemical profile of those found near J.R.’s body.The United States District Court for the Middle District of Florida conducted the trial. The defendant challenged the admissibility of Facebook messages as evidence of intent and prior bad acts, the use of photographs showing him in jail attire, and various aspects of the forensic evidence. The court admitted the challenged evidence, issued limiting instructions to the jury, and denied a motion to continue the trial. The jury convicted the defendant on counts of distributing fentanyl resulting in death and possession with intent to distribute. The court sentenced him to life imprisonment on the first count and ten years on the second. The district court also denied a motion for a new trial, rejecting claims of evidentiary errors and discovery violations.On appeal, the United States Court of Appeals for the Eleventh Circuit reviewed evidentiary rulings, sufficiency of the evidence, and the constitutionality of the mandatory life sentence. The appellate court held that the Facebook messages were properly admitted as probative of intent, that any error in admitting jail photographs was harmless, and that sufficient evidence supported the conviction. The court also found no reversible discovery or Brady violations, and no plain error in the imposition of a mandatory life sentence under 21 U.S.C. § 841(b)(1)(C). The convictions and sentence were affirmed. View "USA v. Defilippis" on Justia Law

The defendant was serving a term of supervised release after prior convictions for drug and firearm offenses. While on supervision, he was alleged to have committed new offenses, including strangulation and assault and battery of a family member, based on an incident with his then-girlfriend, Jessica Rodriguez, in May 2021. Ms. Rodriguez did not report the incident to law enforcement until over a year later, in June 2022, saying she had become fearful of the defendant. The evidence at the revocation hearing included her testimony, corroboration by her daughter, text messages in which the defendant appeared to admit and apologize for the conduct, and photographs of Ms. Rodriguez’s injuries. The defendant denied strangling or striking Ms. Rodriguez, offering an alternative explanation for the events, but the district court found his testimony not credible.Previously, the United States District Court for the Eastern District of Virginia had revoked the defendant’s supervised release and imposed an 18-month sentence after similar violations. The new violations resulted in another revocation petition, but the resolution of the matter was delayed for several years due to continuances while related state charges were pending. Ultimately, in January 2025, the district court held hearings, credited the testimony of Ms. Rodriguez and her daughter, and found by a preponderance of the evidence that the defendant had violated the mandatory condition not to commit new crimes. The court sentenced him to 24 months in prison.On appeal, the United States Court of Appeals for the Fourth Circuit affirmed the district court’s revocation of supervised release, holding there was no clear error in finding the violations or in crediting the complainant’s testimony after considering all relevant evidence. However, the Fourth Circuit vacated the 24-month sentence and remanded for resentencing, because the district court failed to address the defendant’s non-frivolous argument that he should receive credit for an additional 19 months he spent on supervised release while the revocation petition was pending. View "US v. Mills" on Justia Law

Two defendants were implicated in the 1985 kidnapping, rape, and murder of a woman in California. Evidence showed that they were previously involved in a string of armed robberies and planned to escape law enforcement by stealing a vehicle from a shopping center parking lot. They kidnapped the victim, drove her hundreds of miles, sexually assaulted her, and killed her before disposing of her body in a canal. Forensic evidence, including eyewitness testimony and DNA analysis, linked both men to the crimes. Both were arrested years later after advances in DNA technology allowed for retesting of biological evidence.The Sacramento County Superior Court tried the defendants together with separate juries. Each was found guilty of murder, rape, and kidnapping, with special circumstances for kidnapping-murder, robbery-murder, and rape-murder. One defendant was also convicted of sodomy with a sodomy-murder special circumstance. Both were sentenced to death after separate penalty phase trials. The court also imposed various prison terms and restitution fines, staying the execution of the prison sentences.The Supreme Court of California reviewed the case on automatic appeal. It affirmed the convictions of both defendants and the death sentence for one. However, it reversed the death sentence for the second defendant, finding that subsequent changes in the law—specifically regarding the competency of defendants with mental illness to represent themselves—required reversal of his sentence, including the death judgment. The court also vacated any balance of restitution fines for both defendants, pursuant to recent statutory amendments. The case was remanded for further proceedings as to the sentencing of the second defendant. View "P. v. Bertsch" on Justia Law

An adult woman was staying with her elderly mother at her stepfather’s home in Evanston, Wyoming. When her stepsister arrived to retrieve their father’s wallet at his request, she was denied entry. After police arrived to keep the peace, the woman, with her mother as a passenger, slowly backed a Tesla out of the garage, striking her stepsister, who was standing in the driveway. The victim suffered bruising and hip pain, later confirmed by an emergency room visit. The woman, when asked by officers to provide her driver’s license, vehicle registration, and proof of insurance, refused, stating she was contacting her attorney. The officers eventually left and referred the matter to the district attorney.The State charged the woman with felony aggravated assault and battery, and misdemeanor interference with a peace officer. After a two-day jury trial in the District Court of Uinta County, the jury found her guilty on both counts. The court sentenced her to jail and imposed a fine. She appealed, arguing that the district court erred by refusing to give her proposed jury instruction defining “serious bodily injury,” and asserting that the evidence was insufficient to support either conviction.The Supreme Court of Wyoming affirmed the convictions. The court held that under Wyoming law, a “motorized vehicle” is a “deadly weapon” by definition, regardless of the manner in which it is used. Therefore, the district court did not err in declining to give the jury an instruction on “serious bodily injury.” The court also found that sufficient evidence supported the aggravated assault and battery conviction, as the woman knowingly caused bodily injury with a deadly weapon. Finally, the court held that her refusal to provide the requested documents to officers constituted interference under Wyoming law. The convictions were affirmed. View "Mayeux v. The State of Wyoming" on Justia Law

Nathaniel Martin was a passenger in a vehicle stopped by a United States Forest Service law enforcement officer in the Monongahela National Forest after the vehicle was found illegally parked on a single-lane bridge. The officer, Joshua Radford, initially cited the parking violation as the reason for the stop. However, as soon as the stop began, Radford immediately shifted focus, asking about firearms in the vehicle and then further questioning both the driver and Martin regarding other possible contraband. Firearms were discovered, and Martin was eventually arrested after a check revealed prior felony convictions. Notably, the officer did not issue a citation for the parking offense, and the initial minutes of the stop were not captured on bodycam video.After more than two years, Martin was charged in the United States District Court for the Southern District of West Virginia with being a felon in possession of a firearm. He moved to suppress the evidence and his statements, arguing that the stop violated his Fourth Amendment rights because the officer had abandoned the original purpose of the stop. The district court denied the motion to suppress, finding that the officer’s actions remained within the permissible scope of the stop and did not unlawfully extend it. Martin then entered a guilty plea, preserving his right to appeal the suppression ruling.The United States Court of Appeals for the Fourth Circuit reviewed the case. The court held that the officer’s immediate pivot from addressing the parking violation to investigating potential criminal activity was not reasonably related in scope to the original justification for the stop. The court distinguished this situation from prior precedent by noting the absence of circumstances suggesting officer safety concerns. The court reversed the district court’s denial of the suppression motion and vacated Martin’s guilty plea. View "US v. Martin" on Justia Law