Justia Criminal Law Opinion Summaries

Darrick Ferguson pleaded guilty to being a felon in possession of a firearm, in violation of federal law. At the time of sentencing, Ferguson had three prior felony convictions, one of which was under Arkansas law for delivery of a controlled substance—specifically, cocaine. The district court determined that all three prior convictions, including the Arkansas drug conviction, qualified as predicate offenses for an enhanced sentence under the Armed Career Criminal Act (ACCA), which mandates a minimum sentence for individuals with three or more prior convictions for “serious drug offenses.” Ferguson was sentenced to 180 months’ imprisonment.The United States District Court for the Eastern District of Arkansas found that Ferguson’s Arkansas conviction qualified as a serious drug offense under the ACCA. Ferguson appealed, contending that the Arkansas statute under which he was convicted criminalizes a broader range of cocaine isomers than are covered by the federal Controlled Substances Act, and therefore, his conviction should not count as a predicate offense for ACCA purposes.The United States Court of Appeals for the Eighth Circuit reviewed de novo whether Ferguson’s Arkansas conviction qualified as a predicate offense under the ACCA. Applying the categorical approach, the court held that the Arkansas statute criminalizes all cocaine isomers, while the federal law only covers specific ones. Because the Arkansas statute is broader and punishes conduct not included in the federal definition, Ferguson’s conviction does not qualify as a predicate offense under the ACCA. The Eighth Circuit vacated Ferguson’s sentence and remanded the case for resentencing without the ACCA enhancement. The court did not address Ferguson’s argument regarding his burglary conviction since the drug conviction was dispositive. View "United States v. Ferguson" on Justia Law

On the evening of July 4, 2018, a man was killed while sitting with his wife on a Boston sidewalk watching fireworks. The defendant drove his girlfriend’s car with Travis Phillips in the passenger seat. As they passed the victim, Phillips used a laser-guided firearm to shoot and kill him. Security footage captured both the events leading up to and following the shooting. Evidence linked the defendant to the car, including fingerprint and DNA analysis, and to the distinctive clothing he wore that night. Police also discovered and seized a cell phone from the defendant’s bedroom, which contained photographs and metadata relevant to the timeline and location of the shooting.The defendant was indicted on charges of murder in the first degree and unlawful possession of a firearm in the Massachusetts Superior Court. He filed two motions to suppress evidence related to the cell phone, both of which were denied. His theory at trial was that the Commonwealth had failed to prove he was the driver or that he shared Phillips's lethal intent. A jury convicted him on both charges. He appealed directly to the Supreme Judicial Court of Massachusetts, raising arguments about sufficiency of evidence regarding intent, prosecutorial misconduct in statements and arguments, and the legality of the cell phone search and seizure.The Supreme Judicial Court of Massachusetts affirmed the murder conviction, holding that the evidence was sufficient to permit the jury to find shared lethal intent, that the prosecutor’s statements did not exceed permissible bounds, and that the seizure and search of the cell phone were supported by probable cause and not unreasonably delayed or overly broad. However, the court vacated the firearm conviction and remanded for further proceedings because the jury had not been instructed that the Commonwealth bore the burden of proving the absence of a valid firearms license. View "Commonwealth v. Carleton" on Justia Law

Three men, including the defendant, agreed to steal marijuana from a known individual at his apartment. On the day of the incident, the defendant and one accomplice entered the apartment, while the third remained in the car. The accomplice took the marijuana and left the apartment without the defendant’s knowledge. When the apartment’s occupants realized the theft, they told the defendant he could not leave until the accomplice returned. The defendant, feeling threatened, subsequently used deadly force against two men several minutes after the marijuana had already been taken. The three men later regrouped, and the defendant admitted to the shootings.A grand jury in the United States District Court for the Middle District of Florida indicted the defendant for conspiracy to commit robbery under the Hobbs Act (Count 1), substantive Hobbs Act robbery (Count 2), and using a firearm in relation to a crime of violence resulting in murder (Count 3). At trial, the defendant argued that force was not used to effectuate the taking, asserting that the theft was complete when the marijuana was taken, and that the subsequent use of force did not constitute robbery under the Hobbs Act. The district court denied the defendant’s motions for judgment of acquittal and the jury convicted him on all counts. The court sentenced him to consecutive prison terms, including life for Count 3.The United States Court of Appeals for the Eleventh Circuit reviewed the case. The court held that under the Hobbs Act, robbery requires that force or threatened force be used before or during the taking of property—not solely after the property has been surreptitiously taken and carried away. Because the defendant used force only after the marijuana was stolen, the convictions for Hobbs Act robbery and for using a firearm in relation to that robbery (Counts 2 and 3) were reversed for insufficient evidence, and the sentences for those counts were vacated. The conviction and sentence for conspiracy (Count 1) were affirmed. The case was remanded for correction of the judgment. View "United States v. Grable" on Justia Law

Robbie Dean Fetters was convicted by a jury in 2011 of several serious offenses, including being a felon in possession of a firearm, using or carrying a firearm in furtherance of a drug crime, conspiracy to distribute methamphetamine, distribution of methamphetamine, and possession with intent to distribute methamphetamine. Following his conviction, the United States District Court for the Southern District of Iowa imposed a downward-variant sentence of 320 months’ imprisonment and five years of supervised release. Fetters later developed multiple significant medical conditions, such as cirrhosis, diabetes, and complications with a feeding tube, and is classified by the Bureau of Prisons as a Level Three chronic care inmate.In 2020, Fetters sought compassionate release from the district court, arguing that his health issues warranted a reduction in his sentence. The district court denied the motion, finding that he did not establish that the sentencing factors under 18 U.S.C. § 3553(a) supported release. In 2024, Fetters renewed his motion for compassionate release, emphasizing the progression and severity of his medical conditions. Again, the United States District Court for the Southern District of Iowa denied the request, concluding that his medical needs, while serious, did not amount to “extraordinary and compelling reasons” for release and that the Bureau of Prisons could provide adequate care.On appeal, the United States Court of Appeals for the Eighth Circuit reviewed the district court’s denial for abuse of discretion. The appellate court held that the district court properly exercised its broad discretion, considered both the guideline and BOP definitions of “terminal illness,” and thoroughly evaluated Fetters’s health and criminal history. The court further found that the district court appropriately weighed the § 3553(a) factors and did not err in denying compassionate release. The judgment of the district court was affirmed. View "United States v. Fetters" on Justia Law

An 11-year-old child, L.D., was placed in foster care with Trina Mae Johnson. Over a period of fifteen months, Johnson inflicted severe abuse on L.D., including physical torture, starvation, denial of medical care, and psychological torment. The abuse resulted in significant weight loss, untreated injuries, and lasting trauma. Johnson concealed the abuse, enlisted others in her household to participate, and intimidated L.D. into silence. The abuse came to light when Johnson brought L.D. to a youth shelter, prompting an investigation by child services and the FBI.Johnson and several co-defendants were indicted on charges of child torture, child neglect, child endangerment, and assaulting a minor with a dangerous weapon in both federal and Minnesota state law violations. Some co-defendants pleaded guilty, while Johnson’s sister went to trial. Johnson was unable to accept a plea agreement because it was contingent on both sisters pleading guilty. She ultimately pleaded guilty without an agreement. The United States District Court for the District of Minnesota sentenced Johnson to 216 months in prison, after considering the relevant sentencing factors and victim impact statements. The sentence was below the government’s recommendation but above the prior plea offer.On appeal to the United States Court of Appeals for the Eighth Circuit, Johnson argued that the district court judge’s direct, sympathetic comments to L.D. at sentencing demonstrated judicial bias and violated her due process right to an impartial tribunal. The Eighth Circuit applied plain error review, noting Johnson did not object to the judge’s comments at sentencing or seek recusal. The court held that the judge’s empathetic remarks to the victim did not display deep-seated favoritism or antagonism that would make fair judgment impossible. Finding no plain error or due process violation, the Eighth Circuit affirmed the district court’s judgment. View "United States v. Johnson" on Justia Law

A father was charged in connection with the death of his seven-month-old son, who had been left in his care. On the evening of the incident, the child’s mother was informed that the baby was choking and was taken to a hospital. Medical professionals discovered severe brain injuries, which ultimately led to the child’s death after life support was removed. Expert testimony at trial indicated the injuries were consistent with abusive head trauma rather than accidental choking or gentle shaking, contradicting the father's account. The defense presented alternative expert opinions suggesting the injuries could have resulted from emergency medical treatment or were consistent with the father’s version of events.A Muscogee County grand jury indicted the father for felony murder and cruelty to children in the first degree. Following a jury trial, he was convicted on both counts, with the cruelty to children conviction merged for sentencing. He received a life sentence without parole for murder. The trial court denied his amended motion for a new trial after a hearing, finding the evidence supported the jury’s verdict and that the verdict was not contrary to justice or equity. The Court of Appeals transferred the case to the Supreme Court of Georgia.The Supreme Court of Georgia affirmed the conviction. It held that the father was not in custody for Miranda purposes during the initial portion of his police interview, so Miranda warnings were not required until later. Any error in admitting evidence of prior difficulties between the father and the child was deemed harmless, as the evidence was cumulative of other unchallenged testimony. Lastly, the trial court properly exercised its discretion in denying the motion for a new trial, acting as the “thirteenth juror” and citing the applicable legal standards. View "SCOTT v. THE STATE" on Justia Law

In this case, a woman was convicted by a jury in 2014 on multiple counts related to the physical abuse of her infant son, including cruelty to children, aggravated battery, and aggravated assault. The evidence at trial established that the infant suffered numerous bone fractures, and medical experts testified the injuries were consistent with abuse. The woman, her then-husband (who was also charged), and her mother were the only caregivers, but her mother was ruled out as a suspect. Both defendants denied harming the child, and both were tried together. The woman was convicted on all counts, while her husband was acquitted.Following her conviction, she filed a motion for a new trial, which was denied by the trial court. Her appeal to the Georgia Court of Appeals was unsuccessful, and the Supreme Court of Georgia denied review. Years later, she filed a habeas corpus petition, arguing that her trial counsel had an actual conflict of interest due to previously representing her co-defendant husband in the same case, which was not disclosed to her. The habeas court found that this conflict prevented her trial counsel from investigating or pursuing the alternative defense that her husband was responsible, and thus adversely affected his representation. The habeas court also found that her appellate counsel’s failure to raise this issue on appeal constituted ineffective assistance, excusing any procedural default.The Supreme Court of Georgia reviewed the record and affirmed the habeas court’s decision. The Court held that trial counsel’s conflict of interest, arising from his prior representation of the co-defendant, significantly affected his performance and deprived the petitioner of effective assistance of counsel. The Court also held that appellate counsel’s failure to raise the conflict of interest on direct appeal was deficient and prejudicial, satisfying the cause and prejudice standard. Thus, the grant of habeas relief and a new trial was affirmed. View "DILLS v. WEAVER" on Justia Law

In this case, the appellant pled guilty to the malice murder of Willie Jacox following a negotiated plea agreement. The shooting occurred after a dispute between the appellant and Jacox, which stemmed from personal tensions. At the time of the incident, the appellant and his co-defendant, who were dating, arranged to meet Jacox. The appellant, feeling disrespected, ambushed Jacox and fired multiple gunshots, resulting in Jacox’s death. Immediate police investigation led to the arrest of both defendants and the recovery of evidence linking the appellant to the crime, including matching ballistics and a positive gunshot residue test. During his guilty plea hearing, the appellant affirmed he understood his rights, had reviewed the plea form with counsel, and was entering his plea voluntarily.After sentencing, the appellant filed a motion to withdraw his guilty plea in the Superior Court of Houston County, arguing that his plea was not knowing and voluntary and that his counsel was ineffective. At the hearing, plea counsel testified to thorough preparation and review of evidence with the appellant, while the appellant claimed he was misled about the sentence and not adequately informed. The trial court found plea counsel’s testimony more credible, determined the appellant understood his plea and its consequences, and denied the motion, concluding there was no manifest injustice.On appeal, the Supreme Court of Georgia reviewed the denial for abuse of discretion. The Court held that the trial court did not abuse its discretion, finding the appellant’s guilty plea was made knowingly, voluntarily, and intelligently under the totality of circumstances. The Court also held that the appellant failed to establish ineffective assistance of counsel, as the trial court was entitled to credit plea counsel’s testimony over the appellant’s. Accordingly, the judgment denying the motion to withdraw the guilty plea was affirmed. View "MURRAY v. THE STATE" on Justia Law

Tony Adams, Jr. was charged and convicted for the stabbing and shooting death of his mother, Belinda Woodson, in Dooly County, Georgia. On May 10, 2018, Adams lived with his mother and stepfather, Tyrone Woodson. After a day of escalating domestic tension and police visits, Adams stabbed and shot his mother following a dispute. Tyrone witnessed part of the assault, and neighbors heard gunshots and saw Adams outside with a firearm. Adams also shot himself in the arm and later told law enforcement conflicting stories about the events, eventually admitting to placing the gun in Woodson’s hand to create a defense. Physical evidence and Adams’s own statements linked him to the crime.After a jury trial in the Superior Court of Dooly County, Adams was found guilty on all counts, including malice murder, felony murder, aggravated assault, and possession of weapons during the commission of felonies. He was sentenced to life without parole and additional consecutive sentences. Adams’s initial motion for a new trial was denied by the trial court, which determined that Adams’s counsel did not render ineffective assistance, and found no reason to conduct a post-judgment competency hearing. The court relied on a pretrial mental health evaluation that found Adams competent and his symptoms feigned, and on counsel’s testimony that Adams showed no signs of incompetence.The Supreme Court of Georgia reviewed Adams’s appeal. It held that Adams’s trial counsel did not perform deficiently by failing to further investigate competency or raise an insanity defense, nor did his comments during direct examination prejudice the outcome. The Court also found no abuse of discretion in the trial court’s denial of a post-judgment competency hearing. However, the Supreme Court vacated Adams’s conviction and sentence for aggravated assault (Count 4) as it merged into the malice murder conviction, and vacated the sentence for possession of a knife during the commission of a felony (Count 6), remanding for resentencing on that count. The judgment was affirmed in part, vacated in part, and remanded. View "ADAMS v. THE STATE" on Justia Law

Tommy Joe Byrd was charged with malice murder, felony murder, and aggravated assault after Jerold Bowden died from stab wounds on May 4, 2020. The evidence showed that the stabbing occurred during a late-night altercation involving several individuals, including Byrd and Bowden, after a car accident and subsequent argument. Witnesses testified that Bowden was stabbed twice by Byrd after Bowden ran away and fell to the ground. Byrd and others then transported Bowden’s body to a relative’s house and left him in the driveway, where he was later discovered deceased. Byrd was arrested several days later and, after waiving his Miranda rights, admitted to stabbing Bowden.A Morgan County grand jury indicted Byrd on three counts. At trial in the Superior Court of Morgan County, the jury found Byrd not guilty of malice murder but guilty of felony murder and aggravated assault. The trial court sentenced Byrd to life without parole for felony murder and merged the aggravated assault conviction. Byrd’s motion for a new trial was denied following an evidentiary hearing.On appeal to the Supreme Court of Georgia, Byrd argued that his conviction should be reversed because the trial court abused its discretion by refusing to grant a mistrial after a State witness briefly mentioned Byrd’s recent release from prison. The Supreme Court of Georgia held that a passing, nonresponsive reference to prior incarceration does not place a defendant’s character in evidence and that the trial court properly exercised its discretion by sustaining the objection and striking the comment, especially since Byrd’s counsel declined a curative instruction. The Court affirmed Byrd’s conviction and sentence. View "BYRD v. THE STATE" on Justia Law