Justia Criminal Law Opinion Summaries

Craig M. Wood was convicted of abducting and murdering 10-year-old Hailey Owens in Springfield, Missouri. After eyewitnesses reported the abduction and provided Wood’s license plate number, police traced it to Wood's residence. Upon searching his home, officers found Hailey’s body in the basement, along with evidence of sexual assault and materials indicating Wood’s sexual interest in young girls. Wood was tried and found guilty of first-degree murder and sentenced to death.The Circuit Court of Greene County presided over Wood’s jury trial, entered judgment, and imposed the death sentence after the jury found multiple aggravating circumstances. The Supreme Court of Missouri previously affirmed Wood’s conviction and sentence on direct appeal in State v. Wood, 580 S.W.3d 566 (Mo. banc 2019). Wood then filed a Rule 29.15 motion for postconviction relief, arguing ineffective assistance of counsel on numerous grounds related to evidence, trial strategy, and mitigation. The motion court held an evidentiary hearing and denied the motion, finding no basis for relief.On appeal to the Supreme Court of Missouri, Wood raised 22 points concerning counsel’s performance and other alleged errors. The court reviewed whether the motion court’s findings and conclusions were clearly erroneous, applying the standard set forth in Rule 29.15(k). The Supreme Court of Missouri held that none of Wood’s claims demonstrated deficient performance or prejudice under the Strickland v. Washington standard. The court found the motion court’s factual determinations and legal conclusions were not clearly erroneous and affirmed the denial of postconviction relief. The judgment overruling Wood’s Rule 29.15 motion was affirmed. View "Wood vs. State of Missouri" on Justia Law

Richard James Johnson was charged with three moving violations in Missouri, including a class E felony charge for driving while intoxicated (DWI) as a persistent offender. The persistent offender charge was based on Johnson’s alleged prior DWI convictions on two separate occasions. Johnson argued that, under recent Supreme Court precedent, any fact that could increase the range of punishment—such as whether prior DWI convictions occurred on separate occasions—must be determined by a jury, not solely by a judge.The Circuit Court of Franklin County agreed with Johnson and dismissed the class E felony DWI charge, finding that the statute governing persistent offender status violated Johnson’s Fifth and Sixth Amendment rights by not requiring a jury determination of the “separate occasions” element. The State sought review from the Missouri Court of Appeals, which denied its writ petition. The State then sought relief from the Supreme Court of Missouri, which issued a preliminary writ of prohibition.The Supreme Court of Missouri reviewed whether section 577.023.2, which assigns the fact-finding responsibility for persistent offender status to the trial judge, is facially unconstitutional. The court held that the statute is not facially unconstitutional because it is possible for the jury to determine the relevant facts in accordance with constitutional requirements. The statute can be applied constitutionally if, after the judge’s initial finding, the jury also finds beyond a reasonable doubt that the defendant is a persistent offender. Therefore, the circuit court lacked authority to dismiss the felony charge on facial constitutional grounds. The Supreme Court of Missouri made permanent its preliminary writ of prohibition, ordering the circuit court to set aside its dismissal of the class E felony DWI charge. View "State ex rel. Catherine Hanaway vs. Hellmann" on Justia Law

While released on bond for a burglary charge, the defendant evaded police during a traffic stop, abandoning his truck in a pond and fleeing on foot. The next day, officers returned and, after a series of encounters involving the defendant and his girlfriend, discovered multiple firearms and ammunition in a nearby SUV, to which the defendant later admitted ownership. Because he had a prior felony conviction, a grand jury indicted him for being a felon in possession of a firearm under federal law. The defendant entered into a plea agreement with the government, recommending certain offense levels and sentencing enhancements, but the agreement did not bind the district court.The United States District Court for the Eastern District of Kentucky received a presentence report that calculated a higher base offense level than the plea agreement had contemplated, after discovering an additional prior controlled substance conviction. Both parties acknowledged the report’s accuracy at sentencing, though they advocated for a lower sentence in line with the plea agreement. The government also acknowledged the court’s independent authority to calculate the guidelines. Ultimately, the district court adopted the presentence report’s range and sentenced the defendant to 110 months, at the bottom of the applicable guidelines range.The United States Court of Appeals for the Sixth Circuit reviewed whether the government breached the plea agreement and whether the sentence was unreasonable. The court held that the government had not breached the plea agreement because the agreement allowed either party to argue for other guideline calculations, and the government did not recommend a higher sentence. The court also found that the sentence was both procedurally and substantively reasonable, as the district court considered the relevant statutory factors and the defendant’s history. The Sixth Circuit affirmed the district court’s judgment. View "United States v. Messersmith" on Justia Law

William White, a federal prisoner serving a lengthy sentence, was transferred from one federal correctional institution to another, spending three days at a federal transfer center in Oklahoma City, where he was held in a Special Housing Unit for security reasons. During this brief transit period, he was not offered, nor did he participate in, any evidence-based recidivism reduction programming required under the First Step Act of 2018 (FSA). White later sought to have his time at the transfer center count toward FSA time credits, which could reduce his period of incarceration.The United States District Court for the District of Maryland denied White’s habeas corpus petition under 28 U.S.C. § 2241. The court found that the Bureau of Prisons’ (BOP) refusal to award FSA time credits for the three-day transfer period was consistent with BOP regulations and policy statements, which generally do not consider prisoners in transit or in certain housing statuses to be “successfully participating” in qualifying programs. The court also rejected White’s claim that his due process rights were violated, holding that the FSA does not create a protected liberty interest in earning time credits during every day of incarceration.Reviewing the case, the United States Court of Appeals for the Fourth Circuit affirmed the district court’s judgment. The Fourth Circuit held that, under the plain text of the FSA, a prisoner is entitled to time credits only for days in which he actually participates in qualifying programming or productive activities. Because White did not participate in any such programming during his three days in transit, he was not statutorily entitled to those time credits. The court further held that the FSA does not create a constitutionally protected liberty interest in earning time credits, so the BOP’s actions did not violate due process. View "White v. Warden of Fed Correctional Ins - Cumberland" on Justia Law

On June 15, 2021, two individuals in Portland, Maine reported being struck from behind by a man who inflicted a sharp pain, with one sustaining a wound on her back. The assailant was described as an African-American male with short spiky hair, wearing a green shirt, and carrying a backpack and tablet. Police identified Saad Zackaria as the likely suspect and located him at the Preble Street Resource Center, where staff permitted officers to enter. Zackaria was found fully dressed near the shower room; after he reentered the shower room with the door partially open, officers observed various sharp objects on the floor, including tweezers, a box cutter, and a wire. Zackaria was subsequently arrested.Following his arrest, Zackaria was charged in June 2021 and indicted in August. The Cumberland County Unified Criminal Docket found him incompetent to stand trial in August 2021, but competency was restored in March 2022. Pretrial motions, including a motion to suppress evidence, were denied after a hearing. Delays arose from counsel withdrawal, attorney illness, and a mistrial due to juror unavailability. Zackaria filed motions to dismiss for delay and for a new bail hearing, both denied in early January 2024. After a jury trial in January 2024, Zackaria was found guilty of aggravated assault with a dangerous weapon and two counts of assault with a dangerous weapon and received a sentence including incarceration and probation.The Maine Supreme Judicial Court reviewed the case and affirmed the judgment. The Court held that Zackaria did not have an objectively reasonable expectation of privacy in the shower room or common area of the shelter under the Fourth Amendment, due to the circumstances of his use and the openness of the space. Additionally, the Court found no abuse of discretion in the trial court’s denial of the speedy trial claim, noting that most delays were not attributable to the State or Zackaria, and that the lengthy pretrial detention did not prejudice the defense. View "State of Maine v. Zackaria" on Justia Law

The defendant was charged in federal court with possession of child pornography under 18 U.S.C. § 2252A(a)(5)(B). He pleaded guilty. At sentencing, a dispute arose over whether he was subject to a ten-year mandatory minimum sentence based on a prior conviction under California Penal Code § 311.11, which criminalizes possession of images depicting a minor “personally engaging in or simulating sexual conduct.” The defendant argued that the California statute was broader than the federal definition of child pornography and therefore should not trigger the federal mandatory minimum.The United States District Court for the District of Wyoming agreed with the government and found that the prior California conviction qualified as a predicate offense, applying the ten-year mandatory minimum sentence required by 18 U.S.C. § 2252A(b)(2). The defendant appealed this decision.The United States Court of Appeals for the Tenth Circuit reviewed the district court’s application of the mandatory minimum sentence de novo. Employing the categorical approach, the appellate court examined whether the elements of the California offense categorically matched the federal generic offense of possession of child pornography. The Tenth Circuit concluded that California Penal Code § 311.11, as interpreted by the California Supreme Court, criminalizes conduct such as “any touching” with sexual intent, which can include nonexplicit, nonsexual images far removed from the federal definition of child pornography. Because the California statute sweeps more broadly than the federal generic offense, the prior conviction does not qualify as a predicate offense under § 2252A(b)(2).The Tenth Circuit held that the mandatory minimum sentence was improperly applied and therefore vacated the defendant’s sentence, remanding the case for resentencing. View "United States v. Griffin" on Justia Law

The defendant was charged with two counts of witness intimidation under Wyoming law, based on statements made during a supervised visit with his two daughters and a subsequent Facebook post. The daughters, aged 14 and 11, were residing at a youth home and scheduled to testify at an upcoming Child in Need of Supervision (CHINS) hearing. During the visit, the defendant made comments such as threatening to take away a tablet if one daughter refused to visit, and asked how the girls would feel if he took their kids away. He also referenced his right to bear arms and posted a Facebook rant containing generically threatening statements. Witnesses at the youth home perceived some of the remarks as threatening, but the daughters themselves did not clearly connect the comments to their upcoming court appearance.The District Court of Uinta County presided over the criminal trial. The jury convicted the defendant on both counts of witness intimidation under Wyo. Stat. Ann. § 6-5-305(a), and the judge sentenced him to concurrent prison terms of four to eight years. The defendant appealed, arguing that there was insufficient evidence to support the convictions and that his statements did not constitute actionable threats intended to influence or intimidate the witnesses in relation to their duty to testify.The Supreme Court of Wyoming reviewed the case. Applying the standard that witness intimidation under the statute is a specific intent crime, the court determined that the evidence did not establish that the defendant’s statements were intended to influence, intimidate, or impede his daughters in their roles as witnesses. The court found no nexus between the alleged threats and the daughters’ participation in the CHINS hearing. Accordingly, the Supreme Court of Wyoming held that the evidence was insufficient to sustain the convictions and reversed both counts. View "Brown v. State" on Justia Law

Amanda Ann Soron, who was unhoused, gave birth outdoors in freezing temperatures behind a retail store. Police discovered her with her newborn, who was still attached by the umbilical cord and subsequently pronounced dead at the hospital. Greenwood Village Police Officer Moreno accompanied Soron in the ambulance and remained present during her treatment, recording procedures and statements with a body-worn camera and documenting evidence during her hospital stay. Four months after the incident, Soron was arrested and charged with child abuse resulting in death. The prosecution sought and obtained a court order for production of all medical records related to Soron and her child’s hospital stay.In the Arapahoe County District Court, Soron moved to prevent the prosecution from accessing her medical records, arguing they were protected by the physician-patient privilege and that the request for records was misleading. After a period during which Soron was found incompetent and later restored to competency, the trial court ruled in her favor. The court found that the child abuse exception to the physician-patient privilege only applied to testimony, not to documents, and that the medical records—including those captured on Officer Moreno’s body-worn camera—were privileged. The court ordered the medical records and camera footage to be sealed and preserved, and denied Soron’s request for a veracity hearing as moot.The Supreme Court of Colorado reviewed the suppression order on interlocutory appeal. It affirmed the trial court’s decision that Soron’s medical records are protected by the physician-patient privilege and that the child abuse exception does not extend to documentary evidence. However, the Supreme Court reversed the portion of the order sealing the body-worn camera footage and related notes, remanding for further factual findings to determine whether that material is privileged or subject to other policy considerations. View "People v. Soron" on Justia Law

Juan Manuel Castorena was charged with first degree murder in Colorado’s Seventeenth Judicial District. At his first trial, a forensic scientist named Yvonne Woods from the Colorado Bureau of Investigation testified regarding DNA evidence. Following that trial, Woods became the subject of an internal and criminal investigation for potential misconduct in DNA analysis, and she was subsequently prosecuted by the First Judicial District Attorney’s Office. Castorena, preparing for a retrial after his conviction was vacated on appeal due to an evidentiary error, requested materials from Woods’s investigation for his defense, specifically seeking the complete investigative file held by the First Judicial District Attorney.After Castorena’s request, the Adams County District Court ordered the First Judicial District Attorney to disclose Woods’s investigative file to Castorena and his attorneys, requiring that the order be served on the First Judicial District Attorney, who was not a party to Castorena’s criminal case. Castorena’s attorneys emailed and mailed notice of the order, but did not serve it pursuant to the requirements for service of process. The First Judicial District Attorney appeared specially to object, asserting lack of jurisdiction and improper use of criminal discovery rules, and sought relief from the Supreme Court of Colorado under C.A.R. 21.The Supreme Court of Colorado held that while a trial court may order a nonparty governmental entity to produce materials during pretrial discovery under Crim. P. 16(I)(c)(2), such an order is only enforceable if the court has obtained personal jurisdiction over the nonparty through proper service. Because Castorena had not properly served the First Judicial District Attorney, the trial court lacked personal jurisdiction, rendering its disclosure order void. The Supreme Court made absolute the order to show cause, vacated the trial court’s order, and remanded for further proceedings. View "People v. Castorena" on Justia Law

The defendant was charged with multiple felony sexual offenses involving a child in Larimer County, Colorado. Over a period of several years, different attorneys for the defendant requested multiple competency evaluations, all of which were completed by various experts who consistently found the defendant competent to proceed. After each evaluation, neither party objected to the conclusions, and the district court made final competency determinations. In May 2025, the defense requested another competency evaluation, supported by a psychological report diagnosing the defendant with several mental health conditions but not opining on competency. The court granted the request, and the evaluation again resulted in a finding of competency. The defense then moved for a second-opinion competency evaluation and a hearing.The Larimer County District Court denied the request for a second-opinion evaluation, reasoning that there were no new indicators of incompetency and that multiple prior evaluations had already found the defendant competent. The court also suggested that the defense’s request was a dilatory tactic and not genuinely warranted. When the defense sought clarification, the court reiterated its denial of a second-opinion evaluation but granted a hearing. The defense subsequently filed a petition under Colorado Appellate Rule 21 to the Supreme Court of Colorado.The Supreme Court of Colorado exercised its original jurisdiction, holding that under Colorado law, once a court-ordered competency evaluation is completed, a timely request for a second-opinion evaluation must be granted. The court found that the district court erred by denying the defense’s request and by retroactively questioning the propriety of the initial evaluation. The Supreme Court made absolute the order to show cause and remanded the case, directing the district court to grant the defense’s request for a second-opinion competency evaluation. View "People v. McGee" on Justia Law