Justia Criminal Law Opinion Summaries

In March 2023, a New York State grand jury indicted a former President on thirty-four counts of falsifying business records in the first degree. The indictment alleged that he orchestrated a scheme to influence the 2016 presidential election by directing his personal lawyer to pay $130,000 to an adult film star to prevent disclosure of an alleged sexual encounter. The payments were disguised as legal fees in business records. After arraignment, the defendant sought to remove the case to federal court under the federal officer removal statute, arguing the conduct was within the color of his office and involved federal defenses. The federal district court remanded the case to state court, finding the prosecution fell outside the scope of federal officer removal jurisdiction. A state court jury subsequently convicted the defendant on all counts.After conviction but before sentencing, the United States Supreme Court issued a decision in Trump v. United States, holding that the President is absolutely immune from criminal prosecution for conduct within his exclusive constitutional authority and that evidence of immunized official acts is inadmissible even when an indictment alleges only unofficial conduct. The defendant then sought leave to file a second, untimely notice of removal in federal court, arguing that the Supreme Court’s decision provided new grounds for removal and established good cause for the delay. The United States District Court for the Southern District of New York denied leave, concluding that good cause had not been shown and that the hush money payments were private, unofficial acts.The United States Court of Appeals for the Second Circuit reviewed the district court’s denial. The Second Circuit held that the district court had not adequately considered issues relevant to the good cause inquiry, including the impact of the Supreme Court’s decision and whether evidence admitted at trial related to immunized official acts. The Second Circuit vacated the district court’s order and remanded for reconsideration of the motion for leave to file a second notice of removal, instructing the district court to address these issues. View "New York v. Trump" on Justia Law

In October 2022, a man crashed his car into a parked vehicle in southeast Washington, D.C. After the collision, the car’s owner confronted him, and as police arrived, the man fled on foot. Officers pursued and apprehended him, discovering a gun with a large-capacity magazine under a vehicle along his escape route and another large-capacity magazine with ammunition inside his car. He was charged with several firearm-related offenses, including possession of a large-capacity ammunition feeding device and unlawful possession of ammunition.The Superior Court of the District of Columbia denied the defendant’s motions to dismiss the large-capacity magazine charges on Second Amendment grounds and to suppress the evidence found at the scene, ruling that the search and seizure were justified. After a jury trial, he was convicted of one count of possession of a large-capacity ammunition feeding device and one count of unlawful possession of ammunition, both based on the magazine found in his car. He was acquitted of other charges. The defendant appealed, challenging the denial of suppression, the sufficiency of the evidence for the large-capacity magazine conviction, the lack of a jury instruction on knowledge, and the constitutionality of the statute.The District of Columbia Court of Appeals reviewed the case. After oral argument, the government moved to vacate the large-capacity magazine conviction due to a change in its position on the statute’s constitutionality, which the court granted. The court affirmed the denial of suppression and upheld the unlawful possession of ammunition conviction, holding that the officers’ entry into the car to seize the magazine was justified under the automobile exception to the warrant requirement, as they had probable cause to believe the car contained evidence of criminal activity. The case was remanded for further proceedings. View "Miller v. United States" on Justia Law

Police responded to a business after several 911 hang-up calls and found the defendant’s mother covered in transmission fluid. The defendant, after a verbal exchange with officers, retreated into an office and refused commands to come out. Officers entered, and a struggle ensued as they attempted to arrest him. The defendant resisted, was tased, and continued to resist while being handcuffed. During the struggle, he bit an officer, causing a serious injury. The defendant claimed he bit the officer because he feared for his life, alleging the officer was impeding his breathing.At trial in the 207th District Court of Comal County, the defendant was charged with assault on a public servant. He requested a jury instruction on the necessity defense, arguing his actions were immediately necessary to avoid imminent harm. The trial court denied this request but included a self-defense instruction. The jury convicted him. On appeal, the First Court of Appeals held the defendant was not entitled to the necessity defense because he provoked the difficulty and, under the self-defense statute, was not justified in using force to resist arrest after he had already resisted. The court also found any error in the self-defense instruction was harmless, as the defendant was not entitled to it under the law.The Texas Court of Criminal Appeals reviewed whether a defendant who illegally resists arrest and then claims necessity to justify assaulting an officer can use that defense. The court held that if a defendant is barred from using self-defense to resist arrest under the statutory resisting-arrest exclusion, he is likewise barred from using the necessity defense for the same conduct. The court overruled its prior decision in Bowen v. State, clarified that the resisting-arrest exclusion in the self-defense statute also applies to the necessity statute, and affirmed the judgment of the court of appeals. View "NAVARRO v. STATE OF TEXAS" on Justia Law

The appellant was convicted of capital murder and sentenced to death after a jury found she intentionally killed a pregnant woman, Reagan Hancock, and removed the unborn child, Braxlynn, in the course of committing or attempting to commit kidnapping. The evidence showed the appellant had a history of faking pregnancies and went to great lengths to convince her boyfriend she was expecting a child, including purchasing a fake belly and staging events. On the day of the offense, she attacked Hancock, inflicted numerous fatal injuries, performed a crude C-section to remove the baby, and was later stopped by law enforcement with the infant, who was not breathing and later died.The case was tried in the 202nd Judicial District Court of Bowie County, Texas. The appellant raised multiple pretrial motions, including for a change of venue and a continuance, both of which were denied. She also challenged the admission of various pieces of evidence and the conduct of the prosecution. The jury found her guilty of capital murder and answered special issues in favor of the death penalty. The conviction and sentence were subject to automatic direct appeal to the Texas Court of Criminal Appeals.The Texas Court of Criminal Appeals reviewed twenty-five points of error, including challenges to the sufficiency of the evidence regarding the kidnapping element, pretrial publicity, evidentiary rulings, prosecutorial conduct, and the scope of expert testimony. The court held that the evidence was sufficient for a rational juror to find the aggravating element of kidnapping or attempted kidnapping, and that the trial court did not abuse its discretion in its evidentiary or procedural rulings. The court found no reversible error and affirmed the conviction and sentence of death. View "PARKER v. STATE OF TEXAS" on Justia Law

In September 2017, John Lacy was shot and killed in Minneapolis. Tescil Romalis Mason-Kimmons was indicted for first-degree murder and faced a potential life sentence. Surveillance footage, witness statements, and physical evidence linked Mason-Kimmons to the crime, but some witness descriptions did not match his appearance. Shortly before trial, Mason-Kimmons’s attorney stated he was unprepared and would provide ineffective assistance if forced to proceed. Mason-Kimmons subsequently pled guilty to second-degree intentional murder and received a 366-month prison sentence.After sentencing, Mason-Kimmons filed a direct appeal, which was stayed to allow him to seek postconviction relief in the Hennepin County District Court. He argued that his guilty plea was involuntary due to ineffective assistance of counsel, specifically that his attorney’s lack of preparedness pressured him into pleading guilty. The district court denied his petition without an evidentiary hearing. The Minnesota Court of Appeals affirmed the denial of his involuntary plea claims but remanded for an evidentiary hearing on the ineffective assistance claim. After further proceedings, the district court again denied relief, finding Mason-Kimmons was not prejudiced by his attorney’s deficient advice. The court of appeals affirmed, concluding there was no reasonable probability Mason-Kimmons would have insisted on going to trial but for counsel’s advice.The Minnesota Supreme Court reviewed the case, focusing on whether Mason-Kimmons was prejudiced by his attorney’s constitutionally deficient advice. The court held that there was a reasonable probability Mason-Kimmons would have gone to trial if not for his counsel’s lack of preparedness and advice to plead guilty. The Supreme Court found both prongs of the Strickland test for ineffective assistance of counsel were met, reversed the lower courts’ decisions, and remanded to allow Mason-Kimmons to withdraw his guilty plea. View "Mason-Kimmons vs. State of Minnesota" on Justia Law

After pleading guilty to federal drug-distribution conspiracy charges in 2012, the defendant was sentenced to ten years in prison followed by eight years of supervised release. He began his supervised release in 2019. In 2022, while still under supervision, he shot and killed a man outside a convenience store, an act captured on security video. He subsequently pled guilty to murder in state court. This new criminal conduct constituted a violation of the conditions of his federal supervised release.Following the murder conviction, the United States District Court for the Eastern District of Michigan revoked the defendant’s supervised release. At the revocation hearing, the court considered the advisory Sentencing Guidelines, which recommended a range of 51 to 63 months, but imposed the statutory maximum of 60 months’ imprisonment. The court ordered this sentence to run consecutively to the defendant’s state sentence. The defendant objected to both the length of the federal sentence and the decision to run it consecutively, but did not object to the court’s consideration of the seriousness of the supervised-release violation.On appeal, the United States Court of Appeals for the Sixth Circuit reviewed the procedural and substantive reasonableness of the sentence. Applying plain-error review to the procedural challenge, the court held that the district court did not treat the seriousness of the supervised-release violation as a mandatory factor, but permissibly considered it as a breach of trust. The court also found no abuse of discretion in the substantive reasonableness of the sentence, noting that the district court considered multiple relevant factors and imposed a within-Guidelines sentence. The Sixth Circuit affirmed the district court’s judgment. View "United States v. Patterson" on Justia Law

Gregory Bonnie was serving a 144-month federal prison sentence in South Carolina, consisting of 120 months for drug trafficking convictions and a consecutive 24 months for violating supervised release, which included a conviction under 18 U.S.C. § 924(c) for possession of a firearm during a drug trafficking crime. While incarcerated, Bonnie sought to earn time credits under the First Step Act (FSA) for the 120-month portion of his sentence related to drug offenses, acknowledging that the 24-month portion for the § 924(c) conviction was disqualifying under the FSA.The Bureau of Prisons (BOP) denied Bonnie’s request, treating his consecutive sentences as a single, aggregate term of imprisonment pursuant to 18 U.S.C. § 3584(c), and finding him ineligible for FSA time credits because his aggregate sentence included a disqualifying § 924(c) conviction. After exhausting administrative remedies, Bonnie filed a habeas petition under 28 U.S.C. § 2241 in the United States District Court for the District of South Carolina. The district court granted summary judgment for the warden, holding that the plain text and statutory context of the FSA and § 3584(c) required aggregation of sentences, making Bonnie ineligible for FSA time credits for the entire 144-month sentence.On appeal, the United States Court of Appeals for the Fourth Circuit reviewed the statutory interpretation de novo. The court held that, under the FSA and § 3584(c), the BOP must treat multiple consecutive or concurrent sentences as a single, aggregate sentence for administrative purposes, including the computation of FSA time credits. Because Bonnie’s aggregate sentence included a conviction under § 924(c), he was ineligible for FSA time credits for any portion of the sentence. The Fourth Circuit affirmed the district court’s judgment denying Bonnie’s habeas petition. View "Bonnie v. Dunbar" on Justia Law

The appellant was convicted of first-degree murder for killing his estranged wife’s 14-month-old son, as well as attempted murder and aggravated assault of his estranged wife’s roommate. The prosecution’s case relied heavily on the testimony of a police officer who witnessed the events. At trial, the appellant represented himself and claimed innocence, alleging a police cover-up. During jury selection, one juror initially indicated on a questionnaire that a family member had been charged with a crime, but then changed the answer to “no.” Decades later, the appellant’s counsel discovered that this juror’s nephew had, in fact, been charged with attempted murder of an infant before the trial, a fact not disclosed during voir dire.The Court of Common Pleas of Dauphin County dismissed the appellant’s third Post Conviction Relief Act (PCRA) petition as untimely, reasoning that the information about the juror’s nephew was available in a 2002 news article and thus not a “new fact.” The court concluded that the appellant failed to show why he could not have discovered this information earlier, and therefore did not meet the requirements for the previously unknown fact exception to the PCRA’s time bar.The Supreme Court of Pennsylvania reviewed the dismissal de novo. It held that the lower court erred by applying a presumption that the appellant knew of the juror’s family connection simply because the information was publicly available. The Supreme Court clarified that the relevant inquiry is whether the appellant actually knew or could have discovered the fact through reasonable diligence, not whether the information was in the public record. The Court vacated the order dismissing the petition and remanded for further proceedings, holding that the appellant was entitled to a hearing to establish whether he met the requirements for the newly discovered fact exception. View "Commonwealth v. Blakeney" on Justia Law

The case involved a defendant who was convicted by a jury of two counts of gross sexual imposition, one a class AA felony and one a class A felony. During jury deliberations, the jury requested to review a recorded interview that was part of the evidence. Because there was no device available for the jury to listen to the recording in the jury room, the district court decided to play the recording in the courtroom. The court then closed the courtroom to the public during this process, reasoning that the jury’s review of evidence constituted deliberations, which required exclusion of the public.The District Court of Dunn County, Southwest Judicial District, presided over the trial and made the decision to close the courtroom. The defendant did not object to the closure at trial but did ask the court to consider whether reviewing evidence was truly deliberation. The court performed a Waller v. Georgia analysis and found that an overriding interest justified closure, and both parties agreed the findings were adequate for the record. The defendant was convicted and sentenced to a 20-year term, with 10 years suspended, and the sentences to run concurrently.On appeal, the Supreme Court of North Dakota reviewed whether the closure of the courtroom during the jury’s review of evidence violated the defendant’s right to a public trial. The court held that the district court erred by treating the jury’s review of evidence as deliberations requiring closure. The Supreme Court found this was a plain and obvious error that affected the defendant’s substantial rights, constituting a structural error. The Supreme Court of North Dakota reversed the judgment and remanded the case for a new trial, holding that the closure of the courtroom under these circumstances violated the defendant’s constitutional right to a public trial. View "State v. Barrett" on Justia Law

A defendant was arrested following a report of sexual misconduct and charged with four counts of gross sexual imposition involving a minor. The victim testified that the defendant’s sexual contact began when she was six years old and continued regularly from 2013 to 2016. The victim’s mother testified that the defendant admitted to an instance of sexual contact in 2013, and the victim’s brother corroborated that the victim disclosed the abuse to him, which he later reported to a school counselor. The case proceeded to a jury trial, where the victim and her family members testified about the frequency and nature of the abuse.The District Court of Burke County, North Central Judicial District, presided over the trial. During jury deliberations, the jury requested to review an audio recording, which was replayed in open court due to the lack of a clean computer for use in the jury room. After the recording was played, the defendant’s attorney moved for a mistrial, alleging that the victim’s mother made audible noises in the courtroom that could have influenced the jury. The court denied the motion, noting that neither the judge, the State, nor defense counsel (apart from the defendant’s own observation) noticed any such noises. The jury found the defendant guilty on all four counts, and each juror affirmed that the presence of others in the courtroom did not affect their verdicts.On appeal, the Supreme Court of North Dakota reviewed whether there was sufficient evidence to support the convictions and whether the district court abused its discretion in denying the motion for mistrial. The court held that the victim’s testimony, even without specific instances for each year, was sufficient to support the convictions. The court also found no actual prejudice from the alleged courtroom noises and concluded the district court did not abuse its discretion. The judgment was affirmed. View "State v. Watterud" on Justia Law