Justia Criminal Law Opinion Summaries

A convenience store employee in Plentywood, Montana, discovered a small bag containing methamphetamine on the store floor during her shift and called law enforcement. Surveillance footage was reviewed, and a deputy identified Shawn Andersen as a person who had been in the area where the bag was found. The deputy did not watch all of the footage but focused on the time around when the bag appeared. Later, another bag of methamphetamine was found in Andersen’s pocket when he was arrested at the county jail. Both baggies tested positive for methamphetamine. At trial, the State’s case relied heavily on the surveillance footage and related testimony to link Andersen to the drugs found at the store.The Fifteenth Judicial District Court in Sheridan County presided over Andersen’s jury trial. During deliberations, the jury asked to review the surveillance footage. While they watched, the State’s legal assistant audibly commented, “There it is,” as the video showed the disputed moment. Andersen’s counsel immediately moved for a mistrial, arguing that the comment could have improperly influenced the jury. The District Court denied the motion, and the jury convicted Andersen on all counts. Andersen was sentenced to a combination of suspended and consecutive sentences for possession of dangerous drugs and possession of drug paraphernalia.The Supreme Court of the State of Montana reviewed whether the District Court abused its discretion by denying Andersen’s motion for mistrial. The Supreme Court held that the legal assistant’s comment constituted improper third-party jury misconduct, creating a presumption of prejudice. Because the District Court neither declared a mistrial nor conducted an inquiry to rebut this presumption, the Supreme Court found this to be an abuse of discretion. The conviction was reversed, and the case was remanded for a new trial on all counts. View "State v. Andersen" on Justia Law

Joe’Veon Penson Willis operated a residence used for drug trafficking with his half-brother. On Christmas Day 2021, the two streamed a Facebook Live video describing their drug business, which drew the attention of federal authorities. Shortly afterward, agents from the ATF and DEA executed a search warrant at their house, discovering significant quantities of methamphetamine and fentanyl, multiple firearms, and drug paraphernalia in various rooms. Further investigation established that Willis had used a straw purchaser to acquire at least some of the firearms.Willis was charged in the United States District Court for the Northern District of Ohio with maintaining a drug premises and two counts of aiding and abetting false statements in the purchase of firearms. He pled guilty without a written plea agreement. At sentencing, Willis objected to a two-level sentencing enhancement for maintaining a drug premises, arguing that it constituted impermissible double-counting because the underlying offense and enhancement addressed the same conduct. He also challenged the attribution of certain drugs found in shared spaces to him. The district court rejected these objections, adopted the presentence report in full, and imposed three concurrent sentences of 135 months, which was below the advisory Guidelines range.On appeal, the United States Court of Appeals for the Sixth Circuit reviewed Willis’s arguments de novo for double-counting and for abuse of discretion regarding substantive reasonableness. The court held that applying the two-level enhancement for maintaining a drug premises, even when the underlying conviction was for that same conduct, was permissible given clear Congressional intent. The court also found the sentence substantively reasonable and adequately supported by the record. Although the court acknowledged a technical error in the length of the firearm-related sentences exceeding statutory maximums, it determined this had no practical effect because all sentences ran concurrently. Accordingly, the Sixth Circuit affirmed the district court’s judgment. View "United States v. Willis" on Justia Law

An undercover law enforcement operation targeted individuals seeking to purchase sex from minors through an online platform known for prostitution ads. An agent created a fake profile of a 45-year-old woman but, upon contact, informed the defendant that "she" was actually 13 years old. Despite multiple text exchanges in which the defendant expressed reluctance to engage with someone underage, he continued the conversation, eventually requesting photos, discussing sexual acts, and arranging a meeting while being repeatedly reminded of the minor’s age. At the meeting site, agents seized his phone, which he attempted to wipe, erasing relevant evidence.The United States District Court for the Northern District of Iowa conducted a trial in which a jury convicted the defendant of attempted sex trafficking of a child and destruction of evidence. The court sentenced him to concurrent terms of 292 months and 240 months’ imprisonment. The defendant appealed, challenging the admission of lay-opinion testimony by the undercover agent regarding the perceived maturity of the fictitious minor’s responses, the denial of his request to contact a juror based on alleged outside influence, and the refusal to grant a downward sentencing variance on grounds of purported sentencing manipulation.The United States Court of Appeals for the Eighth Circuit reviewed the case and affirmed the district court’s rulings. The appellate court held that the agent’s lay-opinion testimony was appropriately admitted under Federal Rule of Evidence 701, as it was based on personal knowledge and aided the jury’s understanding. The court found no abuse of discretion in denying juror contact, as the defendant’s claims were speculative and unsupported by evidence of outside influence. Finally, the court rejected the sentencing manipulation claim, determining that law enforcement had a legitimate goal in targeting those seeking sex with very young minors and that the agent’s actions were not solely intended to enhance the sentence. The judgment was affirmed. View "United States v. Johnson" on Justia Law

Yuri Chachanko and an accomplice committed a series of armed robberies in South Dakota and Montana, leading to federal charges in both states. He was first prosecuted in Montana, where he received a 219-month sentence for Hobbs Act violations and firearm use. After completing that sentence, he faced prosecution in South Dakota, where he pleaded guilty to another firearm offense and was sentenced to 300 months, to be served consecutively after the Montana sentence. Years later, after legislative changes under the First Step Act, Chachanko sought a reduction of his South Dakota sentence, arguing that it was unusually long and that his medical conditions warranted relief.The United States District Court for the District of South Dakota considered his motion. The court focused on whether Chachanko had served at least 10 years of the South Dakota sentence, as required for a reduction based on an unusually long sentence under the Sentencing Guidelines. It found that, although Chachanko had spent 17 years in custody overall, he had only just begun serving the South Dakota sentence, as the sentences were consecutive. The court also found that his medical conditions were adequately managed and did not meet the standard for extraordinary and compelling reasons, and that no combination of circumstances justified relief.On appeal, the United States Court of Appeals for the Eighth Circuit affirmed the district court’s decision. The Eighth Circuit held that the phrase “the term of imprisonment” in the relevant statute and guidelines refers specifically to the sentence imposed by the court reviewing the motion—here, the South Dakota sentence—and not to an aggregate of multiple sentences. As Chachanko had not served 10 years of the South Dakota sentence, he was ineligible for relief on that basis. The court also found no abuse of discretion in denying relief based on medical or other circumstances. View "United States v. Chachanko" on Justia Law

After serving more than a decade in the Illinois state legislature, the defendant established a lobbying and consulting firm and also sold life insurance for a private company. For several years, she correctly filed her tax returns and reported her income. However, beginning in 2014, she significantly underreported her income on her personal tax returns or failed to file altogether, despite substantial earnings from her business and insurance work. She was later terminated from her insurance position for fraudulent activity. The IRS discovered unreported income and issued a notice of tax liability, prompting her to amend one return and enter a payment plan, which she later abandoned.A grand jury indicted her on six counts, including making false statements on tax returns and willfully failing to file returns for herself and her company. The United States District Court for the Northern District of Illinois, Eastern Division, made several evidentiary rulings before and during trial, including excluding evidence of her amended tax return and payment plan, and limiting her expert’s testimony. The jury convicted her on four counts. The court denied her motion for judgment of acquittal and later sentenced her to one year of imprisonment and supervised release. She subsequently filed a motion to modify her sentence to make her eligible for good-time credits, which the district court denied.The United States Court of Appeals for the Seventh Circuit reviewed her convictions and the district court’s evidentiary rulings de novo and for abuse of discretion, respectively. The appellate court held that there was sufficient evidence for a rational jury to find willfulness, affirmed the exclusion of post-offense remedial evidence as within the district court’s discretion, found her challenge to the impeachment ruling waived since she did not testify, upheld the limitation on her expert’s testimony, and agreed that her motion to correct the sentence was untimely and properly denied. The Seventh Circuit affirmed the judgment. View "United States v. Collins" on Justia Law

A driver in Lake Havasu City rear-ended a Jeep that was stopped at a red light, causing the Jeep to be pushed through the intersection and resulting in the death of one of its passengers. The driver’s vehicle also continued through the intersection while the light was red. Prosecutors charged the driver under Arizona’s enhanced penalty statute, which criminalizes certain traffic violations—including running a red light—if those violations result in an accident causing serious injury or death.After a bench trial, the Lake Havasu Consolidated Court found the driver guilty, reasoning that the entire sequence of events—from the rear-end collision to the vehicles coming to rest—constituted a single “accident” under the statute. On appeal, the Mohave County Superior Court reversed the conviction, concluding that the driver’s red-light violation did not cause the fatal accident because the collision occurred before the vehicle entered the intersection and thus before a red-light violation was committed. The State sought further review, and the Arizona Court of Appeals sided with the State, interpreting the statute to cover a continuous chain of events, so long as the accident ultimately resulted from failing to stop at the red light.The Supreme Court of the State of Arizona reviewed the case to clarify the statute’s scope. The court held that a violation of the red-light statute occurs only when a driver enters an intersection against a red light. Therefore, the enhanced penalty does not apply to an accident that occurs before the driver enters the intersection, even if the vehicle subsequently runs the red light. The court vacated the court of appeals' opinion and affirmed the superior court’s order directing an acquittal, holding that the enhanced penalty statute requires the red-light violation to precede the accident causing injury or death. View "STATE OF ARIZONA v GORDON" on Justia Law

The defendant, an adult male in his fifties, was accused of engaging in unlawful sexual contact with his twelve-year-old great-niece while she was staying overnight at his home in October 2020. The victim disclosed the incident to her mother about a year later after family members encouraged her to speak up due to concerns arising from accusations the defendant had made against the victim’s cousin. The matter was reported to law enforcement and later discussed in a forensic interview. The defendant was subsequently indicted and proceeded to a jury trial.During the trial in the Cumberland County Unified Criminal Docket, significant evidentiary disputes arose. The State sought to introduce testimony regarding a subsequent incident in which the defendant allegedly offered a sex toy to the victim and another individual, arguing its relevance to intent and the relationship between the parties. The defense objected, citing prejudice and late disclosure, and initially, the trial court excluded the evidence but left open the possibility of reconsideration. As the trial progressed and new lines of questioning emerged, the court ultimately allowed this evidence, finding no unfair prejudice. The defense also attempted to introduce evidence that the defendant had threatened the victim’s cousin, theorizing it would demonstrate a motive to fabricate the allegations. The court excluded this testimony, finding it irrelevant because there was no evidence the victim knew of the threats or that her family conspired to fabricate the allegations.The jury found the defendant guilty, and the court imposed a sentence of eight years, with a portion suspended and a probation period. On appeal, the Maine Supreme Judicial Court held that the trial court acted within its discretion in admitting the evidence of the subsequent sexual behavior and did not err in excluding the evidence of threats toward the cousin due to lack of relevance. The judgment of conviction was affirmed. View "State of Maine v. Cardona" on Justia Law

After pleading guilty to felony child neglect, the defendant was sentenced to five years’ imprisonment with three years suspended, credit for 375 days already served, supervised probation, and restitution. Following his release, the State alleged that the defendant violated multiple conditions of his probation. At a probation revocation hearing, the defendant waived his right to counsel and admitted the violations, leading the district court to revoke his probation. The court orally stated the defendant would receive credit for two years plus the time he spent in custody after being arrested on the probation violation warrant, which amounted to twenty-four days.The written order issued after the revocation hearing, however, erroneously recorded the credit for time served as “3 years and 34 days” instead of the correct “2 years and 24 days.” The State moved to correct this mistake under North Dakota Rule of Criminal Procedure 36, arguing it was a clerical error that conflicted with the court’s oral pronouncement. The District Court of McHenry County granted the State’s motion, found the original written order contained a clerical error, and issued an amended order reflecting the proper credit. The defendant appealed, arguing that the correction improperly reduced his credit for time served and conflicted with the court’s oral pronouncement. He also asserted his constitutional right to counsel was violated when the court did not appoint an attorney to represent him in the Rule 36 proceedings.The Supreme Court of North Dakota affirmed the district court’s orders. It held that the correction was a permissible exercise of the court’s discretion under Rule 36 to remedy a clerical error in the judgment so that it accurately reflected the oral pronouncement at the revocation hearing. The court also concluded that the defendant’s constitutional right to counsel was not violated because the correction of a clerical error under Rule 36 is not a critical stage of the prosecution. View "State v. Jaeger" on Justia Law

In this case, a man moved in with his girlfriend and her children, including twin daughters who referred to him as their stepfather. After the man lived with the family, one of the twins, M.R., disclosed that he repeatedly sexually abused her when she was six and seven years old. She described being taken to the basement while her mother was asleep, having various sexual acts performed on her, and being shown explicit videos. She did not initially report the abuse due to fear and threats from the man. Eventually, she told her grandmother, which led to a police and medical investigation, forensic interviews, and the discovery of pornography and sex-related items in the home. The man denied the allegations and was indicted on multiple charges. Though the children gave inconsistent statements in family court, at the criminal trial both confirmed the abuse and explained their earlier denial was out of fear and misunderstanding.A Jefferson County jury acquitted the defendant of intimidating a participant in a legal proceeding but convicted him of three counts of first-degree sodomy, two counts of first-degree sexual abuse, and one count of distributing obscene matter to a minor. The Jefferson Circuit Court sentenced him to twenty years in prison, adopting the jury’s recommendation.On appeal to the Supreme Court of Kentucky, the defendant argued that the trial court erred by admitting certain testimony and other acts evidence, denying his motion for a directed verdict on the obscene matter charge, and refusing to instruct the jury on lesser-included offenses. The Supreme Court of Kentucky rejected all arguments. It held that the challenged testimony was properly admitted, the evidence was sufficient to support the obscene matter conviction, the other acts evidence was admissible with proper notice, and the trial court properly declined to instruct on lesser-included offenses. The court affirmed the conviction and sentence. View "MENDEZ V. COMMONWEALTH OF KENTUCKY" on Justia Law

The case involves an incident in September 2020 where Hartsfield met B.B. at a hotel, and B.B. later accused Hartsfield of rape and assault. Both individuals were interviewed by police, and these interviews were recorded on body cameras. The key evidentiary dispute centered on a portion of the body camera video in which a police officer stated his opinion about whether B.B. was telling the truth regarding her allegations against Hartsfield.The Fayette Circuit Court denied the Commonwealth’s motion in limine, which sought to exclude the officer’s recorded opinion about B.B.’s credibility. The court ruled that the entire body camera video was admissible, reasoning that the officer’s statements provided context rather than being offered for the truth of the matter asserted. The Commonwealth appealed this decision. The Kentucky Court of Appeals reversed the trial court, holding that the officer’s comments on the alleged victim’s credibility were inadmissible and that the trial court erred in ordering the wholesale admission of the video.Upon discretionary review, the Supreme Court of Kentucky affirmed the Court of Appeals’ decision. The Supreme Court held that it is generally improper for one witness to opine on the veracity of another witness, whether directly or indirectly, and that such opinions are within the exclusive province of the jury. The Court distinguished prior precedent, concluding that the officer’s statements at issue were not part of an interrogation technique but were testimonial and inadmissible. The Supreme Court also clarified that video evidence must be limited to admissible portions rather than admitted in its entirety if it contains impermissible content. The Court remanded the case for the trial court to grant the Commonwealth’s motion in limine. View "HARTSFIELD V. COMMONWEALTH OF KENTUCKY" on Justia Law