Justia Criminal Law Opinion Summaries

Daniel Jackson was stopped by sheriff’s deputies in Kentucky after they observed his truck with an obscured license plate and learned he was driving without a valid license or registration. After arresting Jackson, deputies searched his truck and found methamphetamine, marijuana, syringes, and digital scales. A subsequent search of the police cruiser’s back seat, where Jackson had been placed, revealed a bag containing fentanyl. Jackson was charged with possession of fentanyl and methamphetamine with intent to distribute.The United States District Court for the Eastern District of Kentucky presided over Jackson’s trial. At trial, Jackson testified that he had been framed by a deputy who allegedly planted the drugs in both his truck and the police cruiser. The jury rejected Jackson’s account and convicted him. At sentencing, the district court found that Jackson’s testimony constituted perjury and applied a two-level obstruction-of-justice enhancement under the Sentencing Guidelines. The court also imposed a five-year term of supervised release, including a condition permitting searches of Jackson’s electronic devices by the probation office. Jackson did not object to this condition at sentencing.On appeal, the United States Court of Appeals for the Sixth Circuit reviewed Jackson’s challenges to both the obstruction-of-justice enhancement and the supervised-release search condition. The court held that the district court’s findings of perjury—falsity, willfulness, and materiality—were not clearly erroneous and that the enhancement was mandatory under the Guidelines. The appellate court also found no plain error in the imposition or explanation of the electronic-device search condition, given the district court’s stated concerns about officer safety and recidivism. Accordingly, the Sixth Circuit affirmed the judgment of the district court. View "United States v. Jackson" on Justia Law

In 2009, after a history of domestic violence and threats, the defendant killed his wife and five young children by cutting their throats and then fled to Haiti, where he was apprehended and confessed. He attributed his actions to “bad spirits” and voodoo spells. Upon return to Florida, he pled guilty to six counts of first-degree murder, waived his right to a penalty-phase jury, and declined to present mitigation evidence. Throughout the proceedings, his competency to stand trial was repeatedly evaluated, with findings alternating between competent and incompetent, but ultimately he was found competent at the time of his plea and sentencing. His defense team, which included both public defenders and later court-appointed attorneys, conducted extensive mitigation investigations, including mental health and cultural background assessments, despite the defendant’s lack of cooperation.The Circuit Court for Collier County imposed six death sentences, finding multiple aggravating factors and twelve mitigating factors, including some evidence of mental illness. On direct appeal, the Supreme Court of Florida affirmed the convictions and sentences, rejecting claims regarding self-representation, aggravator duplication, and the constitutionality of the death penalty. The defendant then filed a motion for postconviction relief under Florida Rule of Criminal Procedure 3.851, raising claims of ineffective assistance of counsel regarding competency and mitigation, and challenging restrictions on access to public records. The circuit court denied all claims after an evidentiary hearing.The Supreme Court of Florida reviewed the appeal from the denial of postconviction relief and a related habeas corpus petition. The court held that claims regarding competency were procedurally barred, as they could have been raised on direct appeal, and that the defendant failed to show ineffective assistance of counsel under the Strickland standard. The court also found no abuse of discretion in the denial of public records requests and rejected the habeas petition alleging ineffective assistance of appellate counsel. The denial of postconviction relief and the habeas petition were affirmed. View "Damas v. State of Florida" on Justia Law

A member of the Lowell police department’s gang unit created an undercover Snapchat account using a “nonwhite” username and bitmoji, aiming to monitor gang activity by befriending users connected to other officers’ undercover accounts. The officer became “friends” with a user believed to be the defendant, though he did not know the user’s identity or race at the time. The defendant posted a video of himself discharging a firearm from a car, which led police to identify and locate him. A search of the defendant’s vehicle uncovered a firearm matching the one in the video and shell casings consistent with those found at the scene. The defendant did not possess a license to carry a firearm.The Lowell Division of the District Court Department charged the defendant with multiple firearms offenses. The defendant sought discovery on a selective enforcement claim, and the court ordered the production of relevant police records and policies. The records showed that all suspects charged from Snapchat investigations with identifiable race were nonwhite. The defendant moved to suppress evidence, arguing racial motivation in the investigation, but a District Court judge denied the motion, finding no reasonable inference of racial motivation. The defendant also moved to dismiss the firearms charges, claiming the resident firearm licensing scheme violated the Second Amendment. Another District Court judge denied this motion, finding the problematic provision severable. The defendant entered conditional guilty pleas, reserving his right to appeal.The Supreme Judicial Court of Massachusetts reviewed the case. It held that the defendant had raised a reasonable inference of selective enforcement under the Commonwealth v. Long framework and remanded for an evidentiary hearing, requiring the Commonwealth to rebut the inference with a race-neutral reason. The court also held that the Commonwealth’s resident firearm licensing scheme was not facially unconstitutional under the Second Amendment, affirming the denial of the motion to dismiss. View "Commonwealth v. Rodriguez" on Justia Law

The defendant was convicted of second-degree murder following the disappearance of his former girlfriend, who was last seen at his apartment on January 12, 2014. The defendant claimed she left his apartment that night to be picked up by her son, but her son denied this, and she was never seen again. Evidence at trial included testimony about her abrupt disappearance, her close relationships, and her uncharacteristic lack of contact and financial activity after that date. Investigators presented circumstantial evidence, including electronic records showing her phone accessed social media from the defendant’s IP address after the time he claimed she left, and testimony about the defendant’s behavior following her disappearance.The Circuit Court of the Second Circuit initially dismissed a 2019 indictment without prejudice, but a second grand jury indicted the defendant in December 2020. The defendant moved to dismiss the second indictment, arguing insufficient evidence, juror bias, and excessive hearsay, but the circuit court denied the motion, finding probable cause. The court also denied motions to suppress the defendant’s police interview and his subscriber name obtained via subpoena, allowing only his name into evidence. At trial, the jury found the defendant guilty, and post-verdict motions for acquittal or a new trial were denied. The defendant appealed to the Intermediate Court of Appeals, raising multiple points of error, and the case was transferred to the Supreme Court of Hawaiʻi.The Supreme Court of Hawaiʻi affirmed the conviction, holding that there was sufficient evidence to support the verdict, the circuit court did not err in admitting the defendant’s statement to police or his subscriber name, and the claims of prosecutorial misconduct, plain error in jury instructions, defects in the indictment, and pre-indictment delay were not established. The court found no abuse of discretion or reversible error in the lower court’s rulings. View "State v. Brown" on Justia Law

A man was charged in 2003 with second-degree murder in Hawai‘i, facing a possible life sentence without parole due to a sentencing enhancement for especially heinous crimes. After initially pleading not guilty, he changed his plea to no contest in 2004, and the court accepted the plea without the enhancement, sentencing him to life with the possibility of parole. Over the next several years, he filed four postconviction petitions, none of which challenged the validity of his plea. In 2019, the court’s records of his 2004 change of plea hearing, including recordings and stenographer notes, were disposed of according to retention policies.In 2021, after learning that no transcript of his change of plea hearing could be produced, the man filed a fifth postconviction petition under Hawai‘i Rules of Penal Procedure (HRPP) Rule 40, now represented by counsel. He argued for the first time that his plea was not made voluntarily, knowingly, and intelligently. The Circuit Court of the Third Circuit, acting as the Rule 40 Court, held an evidentiary hearing and granted relief, vacating his conviction and ordering him held without bail. The State of Hawai‘i appealed, arguing that Rule 40 was invalid, that the court lacked jurisdiction, and that the man’s claims were waived because they could have been raised earlier.The Supreme Court of the State of Hawai‘i held that Rule 40 is valid under its constitutional rulemaking authority and that the Rule 40 Court had jurisdiction. Although the man appeared to have waived his claim by not raising it in earlier petitions, the Supreme Court found that unusual circumstances and the interests of justice warranted review. On the available record, the Supreme Court concluded that the plea was constitutionally valid. The Court vacated the Rule 40 Court’s judgment and reinstated the original conviction and sentence. View "Eason v. State" on Justia Law

A man was accused by his young daughter of repeated sexual abuse when she was five years old, including acts of oral copulation. The daughter delayed reporting the abuse due to emotional attachment to her father and fear of family disruption. After eventually disclosing the abuse to her mother, law enforcement was notified. The defendant denied the allegations, suggesting another individual may have been responsible during a trip abroad.The Superior Court of San Diego County conducted a jury trial. The prosecution presented expert testimony from a social worker to address common misconceptions about child sexual abuse, such as the prevalence of abuse by known individuals and the reasons for delayed disclosure by victims. The expert did not opine on the truthfulness of the specific allegations. The jury found the defendant guilty of two counts of oral copulation of a child 10 years old or younger and acquitted him of other charges. He was sentenced to two consecutive terms of 15 years to life.On appeal to the California Court of Appeal, Fourth Appellate District, Division One, the defendant argued that the trial court erred in instructing the jury on the use of expert testimony, that his counsel was ineffective for not objecting to certain expert statements, and that cumulative error deprived him of a fair trial. The appellate court reviewed the instructional claim de novo and found the jury was properly instructed on the limited use of the expert’s testimony. The court also held that the expert’s statistical testimony was admissible to counter common misconceptions and did not constitute improper vouching. Finding no instructional error or ineffective assistance, the court rejected the cumulative error claim and affirmed the judgment. View "People v. Page" on Justia Law

The defendant pleaded guilty to burglary, theft, and criminal mischief in 2017 and was sentenced to concurrent terms with a portion suspended, as well as ordered to pay restitution and various fees. After serving time in corrections and being released, he began the suspended portion of his sentence in 2020. In 2023, the State petitioned to revoke his probation, citing a new drug charge and several compliance violations, including failure to pay restitution and fees. The defendant admitted to the new criminal charge, and the other alleged violations were dismissed. At issue was whether he should receive credit for the time he spent on probation (“street time”) before revocation, given his failure to make restitution payments during a specific period.The Montana Eighth Judicial District Court found that, despite the lack of documented violations between August 2020 and January 2023, the defendant’s ongoing failure to pay restitution and fees constituted continuous noncompliance. The court denied him any credit for street time, reasoning that his nonpayment reflected a pattern of disregard for court-ordered conditions.The Supreme Court of the State of Montana reviewed the case de novo, focusing on whether the defendant’s nonpayment of restitution, absent evidence of a clear payment schedule or corrective interventions by his probation officer, constituted a violation sufficient to deny street time credit under § 46-18-203(7)(b), MCA. The Court held that, without a specific directive or record of interventions regarding payment, the State failed to establish a violation during the relevant period. Therefore, the District Court erred in denying street time credit. The Supreme Court reversed the lower court’s decision and remanded the case, directing that the defendant be credited with 883 days of street time. View "State v. Powell" on Justia Law

On May 29, 2003, two Blaine County Sheriff’s deputies responded to a domestic disturbance involving Laurence Dean Jackson Jr. in Harlem, Montana. During a pursuit through a field, both deputies were shot; Deputy Rutherford died from a gunshot wound to the chest, and Deputy Janis was severely injured. Jackson, claiming an alcohol-induced blackout, could not recall the events, leaving Janis as the sole eyewitness. At trial, the State relied on Janis’s testimony and physical evidence to argue that Jackson shot both deputies after a struggle. Jackson’s defense presented expert testimony challenging the State’s account, including a theory that the fatal bullet may have been fired by Janis, not Jackson.Following a 17-day trial in October 2004, Jackson was convicted of deliberate homicide and attempted deliberate homicide, receiving life sentences without parole. The Montana Supreme Court affirmed his conviction in 2009, and the U.S. Supreme Court denied certiorari in 2010. In 2011, Jackson filed a petition for postconviction relief in the Seventeenth Judicial District Court, Blaine County, alleging ineffective assistance of counsel. The District Court allowed for additional evidence and expert review but ultimately denied the petition without an evidentiary hearing, finding Jackson’s claims lacked specific factual support as required by Montana law.The Supreme Court of the State of Montana reviewed whether the District Court abused its discretion by denying Jackson’s petition without a hearing. Applying the Strickland v. Washington standard, the Court held that Jackson failed to present established facts showing deficient performance or prejudice by counsel. The Court found Jackson’s claims speculative and unsupported by the record, concluding the District Court acted within its discretion. The Supreme Court affirmed the denial of postconviction relief. View "Jackson v. State" on Justia Law

The defendant, who had been receiving disability insurance benefits due to a medical diagnosis, operated a jewelry business while collecting these benefits. The Social Security Administration (SSA) began investigating after suspecting that the defendant was earning income that could affect his eligibility. The SSA asked the defendant whether he had worked or received income since his diagnosis, to which he responded negatively. However, evidence showed that he had significant gross income from jewelry sales, and the SSA determined that his countable income likely exceeded regulatory caps, making him ineligible for benefits. The defendant was subsequently charged with taking government property and making false statements.The United States District Court for the District of New Mexico presided over the trial. The government presented evidence of substantial gross income and efforts by the defendant to conceal earnings. The defendant did not provide information about business expenses that could have reduced his countable income. The jury convicted him on multiple counts related to theft of government property and false statements. At sentencing, the district court calculated the loss amount, including benefits paid to the defendant’s children and payments made outside the charged period, resulting in a 15-month prison sentence.The United States Court of Appeals for the Tenth Circuit reviewed the case. The court held that the evidence was sufficient for a reasonable jury to find that the defendant’s countable income exceeded the regulatory caps, even without detailed expense information, given the high gross income and lack of contrary evidence. The court also found no reversible error in the jury instructions, as the defendant failed to timely challenge the district court’s reasoning. Regarding sentencing, the court held that it was proper to include reasonably foreseeable payments to the defendant’s children and payments outside the charged period in the loss calculation. Any error in including Medicare premiums was deemed harmless. The convictions and sentence were affirmed. View "United States v. Sandoval" on Justia Law

A confidential informant reported seeing Anthony Miller, known as “Thugsy,” carrying a handgun and selling drugs in Wilmington, Delaware. Police surveilled the area, observed Miller, and attempted to arrest him. Miller fled, resisted arrest, and was subdued. Officers recovered a loaded handgun and drugs, including pills that tested positive for MDMA and cocaine. Miller admitted to selling MDMA and possessing the firearm. He was initially indicted by a New Castle County grand jury for several offenses, including Drug Dealing MDMA (a Class B felony). A subsequent reindictment changed the main drug charge to Drug Dealing Methamphetamine (a Class C felony), reflecting the actual substance involved.Before his suppression motion was heard, Miller entered a plea agreement in the Superior Court of the State of Delaware, pleading guilty to Drug Dealing Methamphetamine, Possession of a Firearm During the Commission of a Felony, and Resisting Arrest. Due to clerical errors, the plea paperwork and colloquy incorrectly identified the drug dealing charge as a Class B felony with a higher sentencing range, even though the court read the correct substance and quantity from the reindictment. Miller was sentenced to a total of seven years of unsuspended prison time. He did not seek to withdraw his plea but appealed, arguing that his constitutional right to be indicted by a grand jury was violated because he pled guilty to an unindicted, more serious offense.The Supreme Court of the State of Delaware reviewed the case for plain error, as Miller had not raised the issue below. The court held that Miller’s substantial rights were not affected because he received significant benefits from the plea, including immediate sentencing and avoidance of a much longer potential sentence. The court found no plain error and affirmed the conviction, but remanded to the Superior Court to consider Miller’s pending motion for sentence reduction. View "Miller v. State" on Justia Law