Justia Criminal Law Opinion Summaries

Matthew Smith was charged with first degree murder following a shooting outside the Press Box bar in August 2012. Multiple eyewitnesses identified Smith as the shooter, both in police lineups and at trial. The lineups included fillers who differed from Smith in age and hairstyle, and in the second lineup, Smith wore a distinctive red and white shirt that witnesses had described the shooter as wearing. Physical evidence included shell casings and a revolver found in a vehicle from which Smith fled, as well as a photograph of Smith in the bar wearing the same shirt. Smith’s mother was excluded from the courtroom during parts of the trial because she was listed as a potential witness.The Cook County Circuit Court denied Smith’s motions to suppress the lineup identifications and to exclude the photograph, and after a jury trial, Smith was convicted and sentenced to 30 years in prison. On appeal, the Illinois Appellate Court reversed the conviction and remanded for a new trial, finding that excluding Smith’s mother violated his right to a public trial. The appellate court also found errors regarding the suggestiveness of the second lineup, a discovery violation in the gunshot residue expert’s testimony, improper closing arguments by the prosecution, and error in sending the photograph to the jury.The Supreme Court of Illinois reviewed the case and held that excluding Smith’s mother did not violate his right to a public trial, as the courtroom remained open to other family members, spectators, and the media. The court further found that the second lineup was not unduly suggestive, the discovery violation regarding the gunshot residue expert did not warrant reversal, the trial court did not abuse its discretion in allowing the jury to view the photograph, and the challenged prosecutorial comments did not constitute reversible error. The Supreme Court reversed the appellate court’s judgment, affirmed the conviction, and remanded for consideration of any remaining unresolved issues. View "People v. Smith" on Justia Law

The case concerns William Coston, who was accused of sexually abusing a minor over several years, beginning when the victim was four years old. The abuse included multiple acts of rape, the introduction of controlled substances, and sexually grooming the child. Initially, Coston was charged with three counts of rape, but the State later amended the charges to include a total of ten counts of rape, one count of introduction of a controlled substance into the body of another person, and one count of sexually grooming a child. The evidence supporting these charges had been available to the defense throughout the discovery process.The Garland County Circuit Court presided over Coston’s jury trial in March 2024. Prior to trial, the State amended the criminal information to add the additional charges. Coston objected to the timing and number of the new charges, arguing that the amendment was arbitrary and created confusion, but he acknowledged that the evidence supporting the charges had been disclosed from the outset. He did not move to strike the amendment or request a continuance. The circuit court overruled his objection, noting that amendments to the information are permitted up to the point the case is submitted to the jury. After trial, Coston was convicted on all counts and sentenced to consecutive terms of imprisonment.On appeal to the Supreme Court of Arkansas, Coston argued that the circuit court abused its discretion by allowing the State to amend the information shortly before trial. The Supreme Court of Arkansas held that the amendment did not change the nature or degree of the offenses, as it merely added counts of the same offense, and that Coston was not unfairly surprised or prejudiced by the amendment. The court affirmed the circuit court’s decision, finding no prejudicial error. View "COSTON v. STATE OF ARKANSAS" on Justia Law

After a minor car accident outside a Safeway parking lot, Brittany Shantel Carrington and her three passengers, including her teenage daughter, became involved in a physical altercation with Brooklyn Brown and Marylynn Jones, the occupants of the other vehicle. The situation escalated from an exchange of insurance information to a brawl. During the fight, Carrington retrieved an umbrella from her car and, according to testimony, used it to strike the windshield of Brown’s vehicle and hit Jones, who sustained injuries. Police arrived and arrested Carrington, recovering the umbrella from her car.The Superior Court of the District of Columbia presided over a bench trial. The trial judge found the facts surrounding the altercation unclear but ultimately credited Brown’s identification of Carrington as the person who broke the windshield and struck Jones with the umbrella. The court found Carrington’s account not credible and determined that she acted out of anger rather than self-defense. Carrington was convicted of simple assault, destruction of property less than $1000, and attempted possession of a prohibited weapon (attempted PPW). She was sentenced to probation and fines, with the execution of the sentence suspended.On appeal, the District of Columbia Court of Appeals reviewed Carrington’s sufficiency of evidence claims de novo. The court affirmed the convictions for simple assault and destruction of property, finding sufficient evidence and no error in the trial court’s credibility determinations or rejection of self-defense. However, the appellate court reversed and vacated the conviction for attempted PPW, holding that the evidence did not establish the umbrella as a “dangerous weapon” under D.C. law in this instance, as there was insufficient proof that it was likely to produce death or great bodily injury in the manner used. View "Carrington v. United States" on Justia Law

A criminal defendant was charged with murder and released on a $1 million bail bond posted by United States Fire Insurance Company. After his release, the defendant appeared at several hearings, sometimes personally and sometimes through his attorney under a Penal Code section 977 waiver, which allows a defendant to be represented by counsel at certain proceedings. On March 15, 2022, the court ordered the defendant to return for all future hearing dates and continued the bond. On April 26, 2022, the defendant’s attorney appeared on his behalf, and the court ordered the defendant to be personally present at the next hearing. The defendant failed to appear on May 18, 2022, citing illness, and again on June 2, 2022, at which point the court vacated the trial date, forfeited the bond, and sent notice to the surety.United filed a motion in the Superior Court of Riverside County to vacate the forfeiture and exonerate the bond, arguing that the court should have forfeited the bond on April 26, 2022, when the defendant first failed to appear without sufficient excuse, and that the June 2 forfeiture was void for lack of jurisdiction. The trial court denied the motion. After summary judgment was entered against United, it filed a motion to set aside the judgment, again arguing lack of jurisdiction. The trial court denied this motion, finding the issue barred by res judicata.The California Court of Appeal, Fourth Appellate District, Division One, reviewed the denial of the motion to set aside summary judgment. The court held that the trial court was not divested of jurisdiction to forfeit the bail bond on June 2, 2022, because the defendant was not required to personally appear on April 26, 2022, and his appearance through counsel was valid under section 977. The order denying the motion to set aside summary judgment was affirmed. View "People v. United States Fire Insurance Co." on Justia Law

The appellant pleaded guilty in 2015 to driving under the influence and resisting arrest, receiving a sentence of incarceration followed by probation. While serving probation for this 2015 case, he was arrested in 2018 for aggravated assault. After his mother posted bail on the new charges, a probation detainer from the 2015 case kept him in custody. He later pleaded guilty to aggravated assault in the 2018 case and was sentenced to a term of imprisonment. The trial court did not credit him for all the time he spent in custody before sentencing, specifically the period he was held solely on the probation detainer after bail was posted in the 2018 case.The Lackawanna County Court of Common Pleas, acting as the PCRA court, granted partial relief by awarding credit only for the period after the detainer was lifted, reasoning that the earlier period of confinement was solely due to the probation detainer in the 2015 case, for which only a probationary sentence was ultimately imposed. The Pennsylvania Superior Court affirmed, holding that the appellant was not entitled to credit for time spent in custody on the probation detainer because no prison sentence was imposed in the 2015 case, and the time was not attributable to the new charges after bail was posted.The Supreme Court of Pennsylvania reviewed the statutory language of 42 Pa.C.S. § 9760(1) and held that a defendant is entitled to credit against a new prison sentence for all time spent in custody as a result of the conduct underlying the new charge, even if the confinement was due to a probation detainer from an earlier case, so long as the conduct leading to the detainer is the same as that underlying the new charge. The Court reversed the Superior Court’s order and remanded for further proceedings to determine if relief could still be awarded. View "Commonwealth v. Phillips" on Justia Law

Two individuals, Mario Cabral and Vanessa Mora, were shot and killed in their home in March 2018. The defendant, who had a child with Cabral and was involved in a contentious custody dispute, was accused of hiring a hitman, Edward Alonso, to kill Cabral. Alonso testified that the defendant offered him money and provided details about Cabral’s residence, but he ultimately did not carry out the murder. The prosecution presented circumstantial evidence, including testimony about the defendant’s acquisition of a .45-caliber gun, photographs of Cabral’s home found on her phone, and statements suggesting her boyfriend, Flores, might commit the murder if Alonso did not. The defendant denied involvement, but the jury convicted her of first-degree murder of Cabral, conspiracy to commit first-degree murder, and criminal solicitation of first-degree murder.The case was tried in the District Court of Doña Ana County, where the defendant objected to the prosecution’s cross-examination about her six-month-old child’s positive methamphetamine test, arguing lack of notice and relevance. The district court allowed limited questioning on this topic. The jury acquitted the defendant of Mora’s murder but convicted her on the other charges.On direct appeal, the Supreme Court of the State of New Mexico reviewed the evidentiary ruling and found that the district court abused its discretion by admitting the inquiry into the child’s drug test, as it was inadmissible under the relevant evidence rules and not justified as rebuttal character evidence. The error was deemed not harmless, given its impact on the defendant’s credibility. The Supreme Court reversed all convictions and remanded for a new trial. The court also held that the convictions for conspiracy and solicitation did not violate double jeopardy and that sufficient evidence supported the murder conviction. Additionally, the court emphasized the public’s First Amendment right to access criminal trials, criticizing the district court’s prohibition of notetaking by observers. View "State v. Cardenas" on Justia Law

A deadly shooting occurred at a house party in Las Cruces, New Mexico, in July 2021. During a chaotic altercation, multiple gunshots were fired, resulting in the death of Nicodemus Gonzales and damage to a vehicle driven by Jayissa Borrunda. Eyewitnesses described seeing the defendant and his cousin brandishing guns with laser sights. Forensic evidence was inconclusive as to which weapon caused the fatal injury. The defendant, who was seventeen at the time, was charged as a Serious Youthful Offender with first-degree (willful and deliberate) murder and other related offenses.The District Court of Doña Ana County acquitted the defendant of first-degree (willful and deliberate) murder but allowed the case to proceed to the jury on first-degree felony murder, predicated on aggravated assault, as well as other charges. The jury convicted the defendant of first-degree felony murder (as an accomplice to aggravated assault), aggravated assault, two counts of conspiracy, and shooting at a motor vehicle. The court imposed a thirty-year sentence for felony murder, an enhanced sentence for aggravated assault, and additional concurrent sentences for the other convictions.The Supreme Court of the State of New Mexico reviewed the case. It held that aggravated assault is a noncollateral felony and cannot serve as the predicate for felony murder; therefore, the defendant’s felony murder conviction must be vacated as a legal nullity. The Court further held that double jeopardy does not bar retrial for felony murder or its lesser-included offenses when a conviction is reversed for a nonexistent crime, as this constitutes trial error rather than an acquittal. The Court also vacated one conspiracy conviction for lack of evidentiary support and reversed the four-year firearm enhancement as unauthorized by statute. The remaining convictions were affirmed, and the case was remanded for further proceedings consistent with the opinion. View "State v. Revels" on Justia Law

A woman who served as the co-leader of a religious group in rural New Mexico was charged with multiple crimes after a twelve-year-old child, E.M., died at the group’s compound. The woman exercised strict control over the group’s members and limited their access to outside medical care. E.M. became seriously ill, was denied food as punishment, and ultimately died after his condition worsened. The child’s death was not reported to authorities until two years later, when other group members alerted police. An autopsy determined the cause of death was a probable infectious disease, but the exact cause could not be identified due to decomposition.The woman was initially indicted on several charges involving two children. The charges relating to another child, M.G., were severed, and she was convicted by a jury on those counts, receiving a 72-year sentence. Shortly after, she entered a plea agreement on the E.M.-related charges, including child abuse resulting in great bodily harm, and was sentenced to 18 years to run concurrently. Later, the M.G.-related convictions were set aside due to a Brady violation, and those charges were dismissed. The woman then filed a habeas petition seeking to vacate her plea in the E.M. case, arguing actual innocence, among other grounds. The district court rejected most claims but granted relief on actual innocence, finding her conduct did not legally constitute great bodily harm.The Supreme Court of the State of New Mexico held that a defendant convicted by plea agreement may assert a freestanding claim of actual innocence, applying the same clear and convincing evidence standard as for convictions after trial. However, the Court found that the district court’s determination of actual innocence was not supported by substantial evidence, as no new affirmative evidence was presented and the district court’s own findings implicated the defendant in the crime. The Supreme Court reversed the grant of habeas relief and remanded the case. View "State v. Green" on Justia Law

A Nigerian citizen who became a lawful permanent resident of the United States in 2005 was placed in removal proceedings after being convicted of conspiracy to commit passport fraud. He had lived in the U.S. for many years, had a long-term partner, and was the father of four U.S. citizen children. His conviction stemmed from a scheme to obtain fraudulent U.S. passports for noncitizens, for which he was sentenced to 27 months in prison. After serving his sentence and briefly fleeing to Canada, he was returned to the U.S. and charged as inadmissible for committing a crime involving moral turpitude. In removal proceedings, he applied for asylum, withholding of removal, and protection under the Convention Against Torture (CAT), claiming past persecution and fear of future harm in Nigeria due to his former union activities and threats from a militia group.An Immigration Judge (IJ) found him inadmissible, denied all forms of relief, and determined that his conviction constituted a particularly serious crime, barring asylum and withholding. The IJ also found his and his partner’s testimony not credible and denied CAT relief, concluding he had not shown a likelihood of torture with government acquiescence. The Board of Immigration Appeals (BIA) affirmed, agreeing with the IJ’s findings and further holding that the absence of an interpreter did not violate due process, that the conviction was a particularly serious crime, and that he was not eligible for a waiver of inadmissibility.The United States Court of Appeals for the Third Circuit reviewed the case. The court held that the BIA misapplied the legal standard for determining a particularly serious crime by failing to consider the elements of the underlying substantive offense in the conspiracy conviction. The court also found that the BIA did not properly analyze the CAT claim under the required legal framework and failed to consider eligibility for a waiver of inadmissibility. The court denied the due process claim but vacated the BIA’s decision and remanded for further proceedings, ordering a stay of removal pending the outcome. View "Amos v. Attorney General United States of America" on Justia Law

The case concerns a man who was convicted of first degree murder with a deadly weapon enhancement and resisting and obstructing an officer after his uncle was found fatally stabbed in the home they shared. The defendant was located by police shortly after the incident, with injuries and physical evidence linking him to the crime. During jury selection, the only Black juror in the venire was removed by the prosecution using a peremptory strike, prompting the defendant, who is also Black, to raise a Batson challenge alleging racial discrimination. The trial court denied the challenge, finding the State’s reasons for the strike—juror distraction due to personal circumstances and apparent disengagement—were race-neutral and not pretextual. The jury ultimately found the defendant guilty, and he was sentenced to 40 years to life.The Idaho Court of Appeals affirmed the conviction, holding that the defendant had not established a prima facie case of discriminatory intent under Batson v. Kentucky. The defendant then sought review by the Supreme Court of the State of Idaho, arguing that the trial court erred in denying his Batson challenge, limiting cross-examination about alternate perpetrators, and restricting his closing argument. He also invoked the doctrine of cumulative error.The Supreme Court of the State of Idaho clarified that, under Hernandez v. New York, once the prosecution offers a race-neutral explanation and the trial court rules on discriminatory intent, the initial prima facie showing under Batson is moot. The court found no clear error in the trial court’s acceptance of the State’s race-neutral reasons for the peremptory strike. The court also held that the trial court did not abuse its discretion in limiting cross-examination or closing argument, and found no cumulative error. The judgment of conviction was affirmed. View "State v. Buck" on Justia Law