Justia Criminal Law Opinion Summaries

Police in Milwaukee searched Michael Yumang’s car and home in 2019 and 2022, finding distribution quantities of methamphetamine, a handgun, and ammunition. Before the 2022 search, a postal inspector intercepted a package containing a quarter pound of meth addressed to Yumang’s residence from California. Yumang admitted to regularly obtaining meth from California and reselling it in Wisconsin. He was charged with three drug-trafficking offenses related to each meth seizure and the intercepted shipment, as well as unlawful possession of a firearm in furtherance of a drug crime.After an indictment and pretrial proceedings, Yumang waived his right to a jury trial and had a bench trial in the United States District Court for the Eastern District of Wisconsin. The government called multiple witnesses, including three forensic chemists who analyzed the seized meth, confirming its purity and quantity. Prior to trial, the government disclosed—subject to a protective order—that the DEA chemist who tested the 2019 meth had been placed on a performance improvement plan in 2023. At trial, Yumang’s attorney sought to cross-examine the chemist about the plan, but the judge ruled the information irrelevant since the performance issues arose years after the chemist’s work on the case. The judge found Yumang guilty on all counts and imposed a sentence of 180 months.On appeal to the United States Court of Appeals for the Seventh Circuit, Yumang argued that briefly closing the courtroom to make a record of the sidebar discussion about the chemist’s performance plan violated his Sixth Amendment right to a public trial, and that the exclusion of the proposed cross-examination was both evidentiary error and a Confrontation Clause violation. The Seventh Circuit held that the five-minute courtroom closure was too trivial to constitute a Sixth Amendment violation and that excluding the cross-examination was neither an evidentiary nor constitutional error. The court affirmed the judgment. View "USA v Yumang" on Justia Law

Charles Cui was charged with bribery and related offenses after he attempted to secure the assistance of Edward Burke, a powerful Chicago alderman, in reversing a permit denial by the Chicago Department of Buildings (CDOB) regarding a pole sign at his commercial property. Cui’s financial interests were jeopardized by the permit denial, which threatened both a lucrative lease with Binny’s Beverage Depot and tax increment financing from the City. To influence Burke, Cui offered to retain Burke’s law firm for property tax appeal work, explicitly seeking Burke’s intervention in the CDOB matter.The United States District Court for the Northern District of Illinois, Eastern Division, presided over a six-week trial in which a jury convicted Cui on all counts: bribery under 18 U.S.C. § 666(a)(2), violations of the Travel Act, and making false statements to the government. The district court admitted evidence over Cui’s objections, including a photoshopped photograph sent to the CDOB, and denied Cui’s post-trial motions for acquittal and a new trial. The court sentenced Cui to 32 months’ imprisonment and applied an obstruction-of-justice enhancement for failing to produce key emails in response to a grand jury subpoena.On appeal, the United States Court of Appeals for the Seventh Circuit reviewed Cui’s challenges to the sufficiency of evidence, jury instructions, evidentiary rulings under Federal Rule of Evidence 404(b), and sentencing. The court held that sufficient evidence supported the convictions, that the jury instructions correctly conveyed the law’s requirements—including the quid pro quo element and the definition of “corruptly”—and that the admission of the photoshopped photograph was not an abuse of discretion. The court also found that the sentencing enhancement and the disparity between Cui’s and Burke’s sentences were justified. The Seventh Circuit affirmed the judgment of the district court. View "USA v Cui" on Justia Law

On July 3, 2021, a group of young women in Topeka, Kansas, were involved in escalating physical and verbal altercations. The confrontation ended with Daisha Butler firing a gun, resulting in the death of 17-year-old N.M., who was shot in the head while running away. Butler had previously purchased the firearm legally, and ballistic evidence linked the shell casing at the scene to her weapon. Witnesses described various fights between two groups and Butler’s eventual admission to firing the gun, allegedly for self-defense and to protect her daughter, though she denied intentionally shooting anyone.The District Court of Shawnee County presided over Butler’s trial. The jury convicted Butler of first-degree felony murder, based on the inherently dangerous felony of aggravated endangering a child, and of aggravated endangering a child itself. The court merged the murder convictions and sentenced Butler to life in prison without parole for 25 years, plus a consecutive prison term. Butler appealed directly to the Kansas Supreme Court, arguing insufficient evidence, errors regarding the admission of prior crimes evidence, improper jury instructions (including self-defense and lesser-included offenses), and cumulative error.The Supreme Court of the State of Kansas affirmed the convictions. It held that the evidence was sufficient for a rational factfinder to convict Butler of aggravated endangering a child and felony murder, clarifying that the State is not required to prove the defendant knew the victim was a minor; only the fact of the victim’s age must be shown. The court found no abuse of discretion in denying a mistrial after a fleeting reference to marijuana possession. Instructional errors regarding lesser-included offenses and self-defense were deemed harmless, and the cumulative error doctrine did not apply, as there was only a single, non-prejudicial error. View "State v. Butler " on Justia Law

The defendant faced fourteen serious federal charges, including multiple counts related to methamphetamine distribution and a firearms offense, which exposed him to the possibility of life imprisonment and asset forfeiture. He, his attorney, and the government negotiated a plea agreement under which the defendant would plead guilty to a single count of methamphetamine distribution in exchange for dismissal of the remaining charges. However, at the scheduled change-of-plea hearing, the defendant hesitated and expressed a need for further information before deciding to enter a guilty plea. His attorney, citing a breakdown in their relationship, requested to withdraw from the case.The United States District Court for the District of Kansas held an ex parte discussion with the defendant and his attorney to address the attorney’s request. During this conversation, the court explained possible consequences if the attorney withdrew, including potential delays and the government’s ability to withdraw its plea offer. The defendant ultimately decided to proceed with the plea agreement. The district court then conducted the plea colloquy but failed to explicitly inform the defendant of his right to appointed counsel if he could not afford one, as required by Federal Rule of Criminal Procedure 11(b)(1)(D). The defendant did not object to this omission at the time.On appeal, the United States Court of Appeals for the Tenth Circuit considered whether the district court improperly participated in plea negotiations and whether the failure to explicitly advise the defendant of his right to appointed counsel warranted reversal. The Tenth Circuit held that the district court did not participate in plea negotiations by merely advising the defendant about the status of the plea offer and available options regarding representation. The court further held that the omission regarding the right to appointed counsel did not affect the defendant’s substantial rights because he had previously been informed of this right and demonstrated an understanding of it. The conviction was affirmed. View "United States v. Eckstein" on Justia Law

The defendant faced four criminal charges in separate cases—three for theft (shoplifting) and one for interference with official acts following an arrest. As part of a single plea agreement, he pled guilty to two theft charges; in return, the State dismissed the remaining two cases, with the defendant agreeing to pay costs in the dismissed cases. The Iowa District Court for Polk County sentenced the defendant in the two theft cases, dismissed the other two, and ordered him to pay costs for the dismissed cases, including indigent defense recoupment and filing fees.After the district court’s dispositional orders, the defendant appealed, challenging the court’s authority to assess costs in the dismissed cases. The Iowa Supreme Court granted discretionary review to address this issue. The State conceded that no statute authorized the district court to impose costs in dismissed criminal cases. The Supreme Court examined relevant statutory provisions, noting that neither Chapter 815 nor Chapter 910 of the Iowa Code allows for assessment of costs against a defendant when a case is dismissed, as such authority was repealed in 2012.The Iowa Supreme Court held that parties cannot confer statutory authority on the court through a plea agreement for a disposition not authorized by statute. Accordingly, the district court’s orders assessing costs in the dismissed cases were ultra vires and invalid. The Supreme Court vacated the convictions, sentences, and dispositional orders, and remanded the cases. On remand, the State may elect either to vacate only the unauthorized cost orders while enforcing the remainder of the plea bargain, or to vacate the entire plea agreement and all resulting orders, with the option to reinstate any dismissed charges. View "State of Iowa v. Pagliai" on Justia Law

The case concerns the prosecution of a father charged with first and third degree sexual assault of his 5-year-old biological daughter. The child disclosed the alleged abuse to her older brother, who then informed their mother. The day after the disclosure, the father visited the mother’s home and, upon hearing the brother repeat the accusation, physically assaulted and threatened to kill the brother if he repeated the allegation. The mother delayed reporting the incident to law enforcement for about a month. During pretrial proceedings, the court excluded evidence of another accusation involving a different child but permitted testimony about the father's assault and threat against the brother.Following a jury trial in the District Court for Douglas County, the defendant was acquitted of first degree sexual assault but convicted of third degree sexual assault of a child and sentenced to imprisonment and post-release supervision. He appealed to the Nebraska Court of Appeals, arguing that admission of evidence regarding the assault and threat was unduly prejudicial under Neb. Rev. Stat. § 27-403. The Court of Appeals reversed the conviction, reasoning that omitting context about the accusation involving the other child created a misleading impression and unfairly prejudiced the defendant, warranting a new trial.On further review, the Nebraska Supreme Court found that the district court did not abuse its discretion in admitting evidence of the defendant’s assault and threat toward the brother. The Court held that this evidence was probative of consciousness of guilt and explained the mother’s delay in reporting the crime. It further determined that any omission regarding the other child’s accusation did not rise to the level of plain error, especially since defense counsel had sought its exclusion. The Supreme Court reversed the Court of Appeals’ decision and remanded with directions to affirm the conviction and sentence. View "State v. Cartwright" on Justia Law

The defendant killed his former high school girlfriend by strangling and cutting her throat after their relationship ended. In the months leading up to the crime, he exhibited signs of emotional distress and had several altercations with the victim and others. On the day of the killing, he took calculated steps to conceal his involvement, including moving the victim’s body, cleaning evidence, and misleading police about their interactions. During trial, the defendant admitted to the killing but argued he was not criminally responsible due to mental illness, presenting expert testimony regarding his psychological state.In the Superior Court, the defendant was convicted of first-degree murder on theories of deliberate premeditation and extreme atrocity or cruelty, along with assault and battery charges. He was sentenced to life without parole. After his conviction, he filed a motion to suppress evidence obtained from searches of his home and vehicle, arguing lack of probable cause, which the court denied. Later, he moved for a new trial, citing newly discovered evidence of developing schizophrenia after the crime. After an evidentiary hearing, a Superior Court judge denied the motion, finding the new evidence did not cast real doubt on the justice of the conviction.The Supreme Judicial Court of Massachusetts reviewed the consolidated appeals from the convictions and denial of the new trial motion. The court held that the lower court did not err or abuse its discretion in denying the new trial or in its evidentiary rulings. It also found the denial of the suppression motion proper, concluding the warrants were supported by probable cause. The court affirmed all convictions and the denial of the new trial motion. However, it held that the sentence of life without parole was unconstitutional for defendants under twenty-one and remanded for resentencing to life with parole eligibility after fifteen years. View "Commonwealth v. Fujita" on Justia Law

A man was stopped by a police officer for a window tint violation while riding as a passenger in a vehicle driven by a family acquaintance. During the stop, the officer observed behavior from the man that suggested narcotics use. The officer searched a bag in the vehicle, which the man identified as his, and found what appeared to be crystal methamphetamine and a used methamphetamine pipe. The man was arrested at the scene, and the driver left. The man was subsequently indicted for possession of methamphetamine, and at trial, he testified that the drugs were not his and that he did not know the driver well, though she was a family friend.At trial in the Circuit Court of Madison County, the State presented evidence including the testimony of the arresting officer and a crime lab analyst. The defendant’s only witness was himself. In closing argument, the prosecutor highlighted that the defendant, who blamed the drugs on the driver, had not called her as a witness, even though she was known to him and accessible through family. The jury found the defendant guilty, and the trial court denied post-trial motions for a judgment notwithstanding the verdict or a new trial.On appeal to the Supreme Court of Mississippi, the defendant argued that the prosecutor’s comments in closing were improper because they referenced his failure to call the driver as a witness. The Supreme Court reviewed the claim for plain error, since no objection was made at trial. The Court held that there was no error because the witness was more available to the defendant than to the State, given her relationship to the defendant’s family. The conviction and sentence were affirmed. View "Hollingsworth v. State of Mississippi" on Justia Law

In December 2022, Mariah Karriem was attacked outside a hookah lounge in Lowndes County, Mississippi by three individuals, including Kierra Wallace, her sister, and her cousin. Karriem was punched, kicked, and struck several times with a glass bottle, sustaining minor injuries that required minimal medical treatment. The attack was recorded on video, and Karriem later identified her assailants as they fled the scene. A longer video of the incident and a Facebook Live recording of Wallace and her sister admitting to the assault were admitted into evidence.The case was tried before the Lowndes County Circuit Court, where the jury found Wallace guilty of aggravated assault. She was sentenced to twenty years in the custody of the Mississippi Department of Corrections, with five years suspended and five years of post-release supervision. Following sentencing, Wallace filed a motion for judgment notwithstanding the verdict or for a new trial, arguing, among other things, that newly discovered video evidence exculpated her. The trial court held a hearing and found the new video was cumulative of evidence already presented and not exculpatory, denying the motion.On appeal, the Supreme Court of Mississippi reviewed Wallace’s claims regarding a defective indictment, constructive amendment of the indictment, sufficiency of the evidence, and denial of the motion for a new trial. The Court held that the indictment was not defective, as it did not conflate intent elements and Wallace’s defense was not prejudiced. The Court found Wallace was estopped from challenging a jury instruction due to the invited-error doctrine. Reviewing the evidence de novo, the Court found it sufficient for a rational juror to convict. It also held the trial court did not abuse its discretion in denying a new trial. The conviction was affirmed. View "Wallace v. State of Mississippi" on Justia Law

A former elected county prosecutor in Kentucky’s 21st Judicial Circuit was charged with Honest Services Wire Fraud, violations of the Travel Act, and Federal Program Bribery. The charges stemmed from an arrangement with a young woman, M.H., who repeatedly faced legal troubles. Evidence showed that the prosecutor agreed to help her with matters such as getting warrants withdrawn, charges reduced, and release from jail, in exchange for sexual acts and explicit images. The FBI discovered the scheme, leading to federal prosecution. At trial, the government presented incriminating text messages, testimony from M.H., and law enforcement, while the defendant claimed he did not solicit images and that M.H. was assisting in investigations—a claim disproved by evidence.The United States District Court for the Eastern District of Kentucky oversaw the jury trial, which resulted in convictions on all counts. The court sentenced the defendant to 41 months in prison and imposed supervised release conditions, including refraining from excessive alcohol use. On appeal to the United States Court of Appeals for the Sixth Circuit, the defendant challenged the exclusion of certain testimony about Kentucky law, sufficiency of the evidence on several elements, the federal funding nexus for the bribery charge, the supervised release condition, and the sentencing court’s refusal to consider “collateral consequences.”The Sixth Circuit held that the district court did not abuse its discretion or violate constitutional rights in excluding expert legal opinion testimony and that the jury was properly instructed on the meaning of “official acts.” The court found overwhelming evidence supporting the verdict, including proof of a quid pro quo and an interstate nexus. The federal funding requirement was satisfied by evidence that the state received sufficient funds. The supervised release condition and sentencing decisions were not plainly erroneous. The Sixth Circuit affirmed the district court’s judgment in all respects. View "United States v. Goldy" on Justia Law