Justia Criminal Law Opinion Summaries

The case involves a defendant who, after a series of threatening incidents toward his former girlfriend, attacked her and her friend, Daniel Martinez, outside her workplace. The defendant dragged his ex-girlfriend by the hair while wielding a knife. When Martinez intervened, the defendant stabbed him multiple times. These events led to the defendant being charged and later convicted of several offenses, including the attempted murder of Martinez, assault with a deadly weapon, stalking, and battery involving a dating relationship. He was acquitted of the attempted murder charge related to his ex-girlfriend. Enhancements for personal use of a deadly weapon and infliction of great bodily injury were found true, and the defendant was sentenced to 25 years and eight months in prison.Following his conviction, the defendant filed a petition for resentencing under Penal Code section 1172.6, arguing that his case might qualify for relief under changes to the law that limited certain doctrines of murder liability. The Los Angeles County Superior Court denied his petition at the prima facie stage, reasoning that the defendant was convicted as a direct perpetrator with intent to kill, not under any vicarious liability theory such as the natural and probable consequences doctrine. The court also declined to act on his request for recall of sentence under section 1172.1.The Court of Appeal of the State of California, Second Appellate District, Division Six, reviewed the case de novo. It affirmed the denial of the section 1172.6 petition, holding that the record of conviction conclusively established the defendant’s ineligibility for relief because he was not convicted under a theory of vicarious liability. The appellate court also dismissed the portion of the appeal pertaining to the section 1172.1 request, finding it was not an appealable order. View "People v. Anaya" on Justia Law

Bryan Repple was arrested for driving under the influence of alcohol by a Maitland police officer in Maitland, Florida. After the arrest, the officer transported Repple to a breath test facility located outside the city limits, in Orange County, where the officer read the statutory implied consent warning and requested Repple to submit to a breath test. Repple complied, and the test revealed an illegal breath-alcohol level. The central issue in the case was whether the officer, acting outside his municipal jurisdiction when requesting the breath test, had legal authority to do so under Florida law.The matter first came before a Florida trial court, which granted Repple’s motion to suppress the breath test results, finding that the Maitland officer lacked authority to request the test outside his jurisdiction. The Sixth District Court of Appeal affirmed this suppression order, concluding that no legal basis existed for the officer’s extraterritorial action, and rejecting the State’s argument that a continuing investigation exception applied. The district court noted no evidence of a mutual aid agreement and found no statutory or judicial authorization for such extraterritorial police power. The Sixth District certified a direct conflict with a decision by the Fifth District Court of Appeal in State v. Torres, which had held that a municipal officer could request a breath test outside his jurisdiction as part of a continuing DUI investigation.The Supreme Court of Florida reviewed the case based on the certified conflict. It held that, under Florida’s implied consent law, a municipal police officer who makes a DUI arrest within his jurisdiction is implicitly authorized to request a breath test outside his jurisdiction when necessary to complete the statutory process. The Court quashed the Sixth District’s decision in Repple and approved the result in Torres, clarifying that the officer’s authority arose by necessary implication from the statute. View "State v. Repple" on Justia Law

A motel guest noticed a person he did not know walking alongside him as he retrieved an item from his car. When the guest returned to the motel entrance, he used his keycard to unlock the door. At that moment, the other individual quickly grabbed the keycard from the guest’s hand and ran into the motel. The guest followed, asking the individual to go to the front desk to resolve the situation. The individual instead threw the keycard, ran out, and was later found exiting a motel room that was not his. After a short chase, the guest and a motel manager detained him until the police arrived. Throughout the encounter, there were no threats or other contact beyond the grabbing of the keycard.The case was tried in the Baker County Circuit Court, where the defendant was charged with third-degree robbery under Oregon law, which requires the use or threatened use of physical force upon another person during a theft. The defendant moved for a judgment of acquittal, arguing that the evidence did not show he used or threatened “physical force.” The trial court denied this motion, relying on prior Oregon Court of Appeals precedent interpreting “physical force” broadly. The defendant was convicted. The Oregon Court of Appeals affirmed, concluding its own precedent controlled.The Supreme Court of the State of Oregon reviewed the case. The court held that the legislature intended “physical force upon another person” in the robbery statute to mean contact that either causes bodily harm or is reasonably capable of creating a sense of fear or danger that such harm will occur. The court found that the defendant’s actions—quickly grabbing the keycard without other contact or threat—did not meet that standard. The Oregon Supreme Court reversed the decisions of the lower courts and remanded the case for further proceedings. View "State v. Williams" on Justia Law

Jonathan Russell Wright was convicted by a jury in 2012 for possession with intent to distribute cocaine base, a federal offense, and sentenced to life imprisonment under the Controlled Substances Act. The life sentence was imposed due to three prior convictions under Arkansas law for cocaine-related offenses, which triggered a mandatory minimum enhancement. Years later, Congress enacted the First Step Act, which reduced mandatory minimum penalties for certain drug offenses but did not apply retroactively. Wright sought a sentence reduction in 2024, arguing that changes in law, including the First Step Act and recent case law, created a gross disparity between his sentence and what he would receive today. He claimed his prior Arkansas convictions should no longer qualify as predicate offenses for enhancement.The United States District Court for the Eastern District of Arkansas-Central granted Wright’s motion in part, reducing his sentence to 420 months and imposing ten years of supervised release. The court acknowledged the disparity created by the First Step Act as an “extraordinary and compelling reason” for reduction but rejected Wright’s argument that his prior Arkansas convictions could not serve as predicate offenses, citing prior decisions. Wright appealed, arguing for a lower sentence and challenging the district court’s treatment of his prior convictions and its weighing of sentencing factors.The United States Court of Appeals for the Eighth Circuit reviewed the case, first addressing whether President Biden’s commutation of Wright’s sentence to 330 months mooted the appeal. The Eighth Circuit held that the commutation did not moot the case, as courts retain authority over judicial sentences. On the merits, the court found that Wright’s Arkansas convictions no longer qualify as predicate offenses under federal law and that the district court abused its discretion by failing to consider this legal development. The Eighth Circuit vacated Wright’s sentence and remanded for resentencing consistent with its ruling. View "United States v. Wright" on Justia Law

In 2020, an activist named Sir Maejor Page created and operated a Facebook page for an organization called Black Lives Matter of Greater Atlanta (BLMGA), which he registered as a nonprofit in Georgia and obtained tax-exempt status. After failing to file required tax forms for three years, BLMGA’s tax-exempt status was revoked, but the organization continued to appear as a nonprofit on Facebook and receive donations. Following the death of George Floyd, donations surged to over $490,000. Page assured donors that the money would support protests and related activities, but he instead used the funds for personal expenses, including luxury items, a house, home renovations, firearms, and hiring a prostitute.The United States District Court for the Northern District of Ohio indicted Page on one count of wire fraud and three counts of money laundering, alleging he defrauded donors by misrepresenting the intended use of their contributions. At trial, Page testified in his defense, but the jury found him guilty on all counts. During sentencing, the district court adopted the U.S. Probation Office’s recommendations, overruling Page’s objections regarding obstruction of justice, loss amount, and number of victims. The court imposed a sentence of 42 months’ imprisonment on each count, to run concurrently, followed by three years of supervised release.The United States Court of Appeals for the Sixth Circuit reviewed Page’s convictions and sentence. The court held that there was sufficient evidence to support the wire fraud and money laundering convictions, finding Page’s misrepresentations induced donations and that the funds were used for personal benefit. The court also upheld the district court’s evidentiary rulings and sentencing enhancements, concluding there was no plain or prejudicial error. Accordingly, the Sixth Circuit affirmed Page’s convictions and sentence. View "United States v. Page" on Justia Law

Richard Neil Burkett was involved in a physical altercation with his brother-in-law at a convenience store in Texas County, Missouri. Witnesses stated that after being separated from his brother-in-law, Burkett pointed a semiautomatic handgun at him, threatened him, and pulled the trigger, although the gun did not fire. Burkett gave several inconsistent accounts to law enforcement, at first denying having a gun, then claiming self-defense, and finally admitting to pointing the gun after the fight was over. At trial, Burkett’s defense was that he never intended to harm his brother-in-law and only sought to scare him, arguing his gun was unloaded and he lacked intent to injure.The Circuit Court of Texas County conducted a jury trial, where Burkett was found guilty of first-degree assault and armed criminal action. During trial, Burkett did not request a self-defense instruction nor object to the jury instructions, and his counsel did not object to the State’s closing argument, which inaccurately stated that intent was not required for first-degree assault. Burkett’s post-trial motion did not raise these issues.The Supreme Court of Missouri reviewed Burkett’s appeal, in which he requested plain error review on two grounds: the lack of a self-defense instruction and the absence of a curative instruction after the State’s misstatement of law in closing argument. The court held that although Burkett may have injected self-defense into the case through his testimony, he failed to request the instruction or object to its absence, and his trial strategy was inconsistent with self-defense. Similarly, Burkett did not object to the State’s closing argument or request a curative instruction. The Supreme Court of Missouri exercised its discretion to decline plain error review for both claims and affirmed the judgment of the circuit court. View "State v. Burkett" on Justia Law

On February 4, 2020, Isis S. Jones engaged in a series of phone calls with D.W. while D.W. was at Victim’s apartment. After a heated argument, Victim drove D.W. to her aunt’s house, during which Jones continued calling. Near their destination, Victim heard a gunshot, stopped her car, and Jones approached the vehicle, hitting the driver’s side window with a gun. D.W. exited and fought with Jones, while Victim drove away, hearing a second gunshot. Police later observed a bullet hole in Victim’s vehicle, and Victim identified Jones as the shooter. Jones was charged with unlawful use of a weapon—specifically, the class B felony of shooting at a motor vehicle—and an accompanying charge of armed criminal action.The Circuit Court of the City of St. Louis conducted a jury trial, during which the jury was instructed to decide if Jones had shot “into” a motor vehicle, which corresponds to a class E felony, rather than “at” a motor vehicle as charged. Jones did not object to this instruction. The jury found Jones guilty of unlawful use of a weapon and armed criminal action. Jones subsequently entered into a sentencing agreement, receiving a 15-year sentence for the weapon charge (execution suspended for probation) and three years for armed criminal action. Jones appealed, arguing for the first time that the variance between the charged offense and the jury instruction led to manifest injustice due to the greater sentence imposed.The Supreme Court of Missouri reviewed Jones’ claim under Rule 30.20 for plain error, which allows discretionary review of unpreserved errors resulting in manifest injustice. The court held that Jones failed to establish substantial grounds that the circuit court committed plain error, as the distinction between shooting “at” and “into” a vehicle did not constitute a facially evident, obvious, and clear error. The court declined plain error review and affirmed the circuit court’s judgment. View "State v. Jones" on Justia Law

Law enforcement in Cass County, Missouri received a report on July 12, 2021, alleging that Israel Barrera molested a fourteen-year-old girl over several years. A subsequent medical examination confirmed that the girl had contracted trichomoniasis, a sexually transmitted disease, and she denied having any consensual sexual partners. Barrera was taken into custody on September 1, 2021, and officers initially seized a urine sample and buccal swab pursuant to a warrant. However, the urine sample was unusable, leading law enforcement to seek new warrants: one to seize another urine sample (warrant 1) and one to test that sample (warrant 2). The urine sample seized under warrant 1 tested positive for trichomoniasis.The Circuit Court of Cass County found that warrant 1 failed to establish probable cause to seize and test Barrera’s urine, and consequently suppressed the urine test results. The court also determined that the good-faith reliance exception to the exclusionary rule did not apply because the supporting affidavit was so lacking in probable cause that a reasonable officer could not rely on it. The court further found warrant 2 unnecessary, as warrant 1 authorized both the seizure and search of the urine. The state appealed this suppression order.The Supreme Court of Missouri reviewed the case and held that the issuing judge had a substantial basis to conclude that probable cause supported the application for warrant 1. The Court found that the corroborative details in the affidavit—such as medical confirmation of the STD and the victim’s denial of consensual partners—provided sufficient factual support for probable cause under a commonsense, totality-of-the-circumstances approach. Therefore, the Supreme Court of Missouri reversed the Circuit Court’s suppression of the urine test results and remanded the case for further proceedings. The Court also affirmed the finding that warrant 2 was unnecessary. View "State v. Barrera" on Justia Law

The defendant was convicted in 2003 of voluntary manslaughter, robbery, possession of a firearm, and received various sentence enhancements, including a prior strike, a firearm enhancement, and seven prior prison term enhancements, resulting in a sentence of 42 years and four months. Two restitution fines of $5,000 each were also imposed. In 2023, following legislative changes, the Department of Corrections and Rehabilitation identified the defendant as eligible for resentencing under Penal Code section 1172.75, which invalidated certain prior prison term enhancements. The defendant sought to have those enhancements stricken and also requested further modifications, including striking the prior strike and firearm enhancement, and imposing a lesser term for the manslaughter conviction.At the Superior Court of Sacramento County, during the resentencing hearing held in October 2024, the court struck the seven prior prison term enhancements, reducing the sentence to 35 years and four months. However, the court declined to strike the prior strike and firearm enhancement, and reimposed the original restitution fines and victim restitution. The updated abstract of judgment noted the restitution fines were “stayed.” The defendant appealed, raising constitutional and statutory challenges to the reimposition of the upper term, the denial of his request to strike the firearm enhancement under section 1385, and the continued imposition of the restitution fine.The California Court of Appeal, Third Appellate District, held that the trial court did not err by reimposing the upper term for voluntary manslaughter without requiring new findings of aggravating circumstances under amended section 1170, subdivision (b), because section 1172.75, subdivision (d)(4) exempts previously imposed upper terms from these requirements. The court also found no abuse of discretion or statutory error in declining to dismiss the firearm enhancement, as no applicable mitigating factors were established. However, the court concluded that the restitution fine originally imposed in 2003 must be vacated under section 1465.9, as more than ten years had elapsed. The judgment was affirmed as modified to vacate the restitution fine. View "P. v. Salstrom" on Justia Law

One defendant in this case was a high-ranking member of the Varrio Fallbrook Locos gang and the Mexican Mafia, while a codefendant acted as a secretary within the gang structure. In December 2013, the defendant participated in a meeting regarding methamphetamine sales, which resulted in the violent assault of another gang member, A.C., after accusations of unpaid debts. Following the assault, the defendant attempted to prevent A.C. from testifying and conspired to arrange the murder of another gang affiliate. The defendant was convicted by a jury of multiple offenses, including assault with a deadly weapon, conspiracy to commit murder, and conspiracy to dissuade a witness, among others. The trial court imposed a lengthy prison sentence and ordered the defendant to pay various fines and ancillary costs, despite defense counsel’s request to consider the defendant’s inability to pay.The Court of Appeal for the Fourth Appellate District, Division One, reviewed the monetary orders. It held that the trial court should have considered the defendant’s ability to pay before imposing ancillary costs but rejected the argument that an ability-to-pay finding was required for punitive fines. The appellate court clarified that fines could still be challenged under the excessive fines clauses of the federal and state constitutions and remanded the case for resentencing and further proceedings regarding the fines and costs.The Supreme Court of California reviewed the case to resolve inconsistent approaches among lower courts concerning court-ordered financial obligations. The Court held that challenges to the amount of criminal fines must be reviewed under the excessive fines clauses of the United States and California Constitutions. Separately, the Court held that, upon request, a sentencing court must consider a defendant’s inability to pay before imposing court operations and facilities assessments, as failing to do so violates equal protection. The judgment was reversed in part and remanded for further proceedings consistent with these holdings. View "P. v. Kopp" on Justia Law