Justia Criminal Law Opinion Summaries

Two plainclothes detectives in Baltimore, acting on a tip about drug activity, observed Robert Gary Moore and another individual near a parked vehicle. When approached, Moore dropped a plastic bag and fled but was apprehended. The police recovered the bag, which was later analyzed in a laboratory report stating it contained cocaine. During Moore’s trial for possession and possession with intent to distribute, the State introduced two chain-of-custody reports: one disclosed before trial and another (the ECU report) disclosed only mid-trial. The latter did not mention the chemist who performed the analysis, raising questions about whether the correct bag was tested. Moore’s counsel did not object to the late disclosure or use the discrepancy in his defense. Moore was convicted by a jury.After his conviction was affirmed on appeal by Maryland’s intermediate appellate court, Moore sought postconviction relief in Maryland state court, arguing that the State’s belated disclosure of the ECU report violated his due process rights under Brady v. Maryland and that his counsel was ineffective. The Maryland trial court initially granted relief under Brady but, upon remand from the intermediate appellate court for further factfinding, ultimately denied both claims, finding that disclosure during trial did not constitute suppression under Brady. Moore’s application for leave to appeal this denial was rejected.Moore then filed a federal habeas petition in the United States District Court for the District of Maryland. The district court found a Brady violation and granted habeas relief, ordering Moore’s conviction vacated unless retried within sixty days. On appeal, the United States Court of Appeals for the Fourth Circuit agreed that the state court had unreasonably applied federal law and that a Brady violation warranted habeas relief. However, it held that federal district courts lack authority to vacate state convictions directly and thus vacated the district court’s order, remanding for a new order consistent with the proper bounds of federal habeas relief. View "Moore v. State of Maryland" on Justia Law

Border Patrol agents observed a suspicious vehicle near the U.S.-Mexico border in Southern California. After the driver, Alex Ruiz, failed to stop for marked Border Patrol units, agents deployed spike strips and eventually apprehended him. Nearby, four individuals without legal immigration status were found hiding. Evidence at trial established that Ruiz transported these individuals, and a co-defendant testified to having coordinated the pickup with Ruiz.The United States District Court for the Southern District of California presided over Ruiz’s trial. The government introduced a prior conviction Ruiz had for transporting illegal aliens, redacting prejudicial details. Ruiz objected, arguing its admission was improper under Federal Rule of Evidence 404(b) and that it was unconstitutional. The district court admitted the prior conviction to show knowledge and lack of mistake, provided limiting instructions to the jury, and took further steps to minimize prejudice, such as not allowing the documents into the jury room during deliberations. The jury convicted Ruiz on all counts, and he was sentenced to thirty-three months in prison and three years of supervised release.On appeal, the United States Court of Appeals for the Ninth Circuit reviewed whether the district court abused its discretion in admitting evidence of Ruiz’s prior conviction under Rule 404(b) and whether its probative value was substantially outweighed by unfair prejudice under Rule 403. The court held the prior conviction was properly admitted to prove knowledge, was not too remote in time, was supported by sufficient evidence, and was sufficiently similar to the charged conduct. The appellate court also found that any prejudice did not substantially outweigh the conviction’s probative value and that Ruiz waived his constitutional arguments by not raising them below. The Ninth Circuit affirmed the district court’s judgment. View "USA V. RUIZ" on Justia Law

A group of individuals, including the appellant, participated in a scheme involving the use of stolen credit cards and fraudulent memberships at a warehouse store to purchase large quantities of cigarettes. The appellant served as the primary account holder for two business membership accounts and was a secondary member on two others. The scheme resulted in over $2 million in cigarette purchases. Following an 85-count indictment, the appellant was charged with conspiracy to commit credit card fraud, several counts of credit card fraud, and aggravated identity theft. After his codefendants pleaded guilty, the appellant proceeded to trial. During the trial, the government presented testimony from victims whose credit cards were used without authorization. The district court granted the appellant’s motion for acquittal on certain counts due to insufficient evidence, and the jury acquitted him on others, but found him guilty of the remaining charges.The United States District Court for the Northern District of Georgia sentenced the appellant, holding him accountable for the total loss amount charged by all members of the conspiracy using the shared credit cards. This figure was calculated in the presentence report and included losses attributable to the codefendants, except for those counts where the appellant was acquitted. The appellant objected, arguing that he should only be held responsible for transactions he personally conducted, but the district court overruled his objection and imposed restitution matching the total loss amount.On appeal, the United States Court of Appeals for the Eleventh Circuit concluded that the district court committed legal error by failing to make individualized findings regarding the scope of criminal activity undertaken by the appellant, as required under the Sentencing Guidelines. The appellate court vacated the appellant’s sentence and restitution order, remanding for resentencing with instructions to determine the loss amount based on the appellant’s own conduct and correct a clerical error in the judgment. View "USA v. Barry" on Justia Law

A 16-year-old individual was criminally charged in Montana with several offenses, including aggravated burglary and assault on a peace officer. The prosecution filed an Information in the District Court, and a hearing was scheduled to decide whether the matter should be transferred to Youth Court, as permitted by Montana law for certain juvenile defendants. Before being arraigned, the defendant moved to substitute the presiding judge, arguing the motion was timely since arraignment had not yet occurred.The Montana Fourth Judicial District Court, Missoula County, denied the substitution motion without prejudice, reasoning that such motions are prohibited in Youth Court actions and would only be considered if the case remained in District Court following the transfer hearing. The court also issued an order for evaluation to assist in the transfer determination, but the order was initially filed under an incorrect cause number. The defendant then petitioned the Montana Supreme Court for a writ of supervisory control, claiming the denial of the substitution motion was erroneous because the case was pending in District Court as a criminal action, not a Youth Court matter.The Supreme Court of the State of Montana reviewed the case. It held that after the State files an Information in District Court, jurisdiction over the criminal matter rests with the District Court, and the action is not a Youth Court case at that stage. The court further clarified that under Montana law, a defendant’s right to substitute a judge in criminal cases may be exercised any time before arraignment, and that the 10-day window for substitution closes at arraignment rather than opening at that point. The Supreme Court granted the petition for supervisory control, set aside the District Court’s order denying substitution, and remanded for further proceedings consistent with its opinion. View "S.L. v. 4th Judicial District Court" on Justia Law

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