Justia Criminal Law Opinion Summaries

A man was involved in an altercation in a McDonald’s parking lot, during which he struck and shot another individual. Surveillance footage captured the incident, and the state charged him with two counts of felonious assault, each carrying firearm specifications. Prior to trial, his attorney requested a jury instruction on self-defense. The trial judge, after viewing the video, indicated skepticism about granting the instruction, telling the defendant that he likely would not qualify for a self-defense instruction because the evidence suggested he may have initiated the altercation. The defendant expressed concern that without the instruction, a fair trial would not be possible, but the judge repeatedly allowed him opportunities to consult with counsel and emphasized that the decision to plead guilty was his alone.Subsequently, the defendant agreed to plead guilty to a reduced charge of aggravated assault with a firearm specification, in exchange for dismissal of the second count and a recommended aggregate sentence of four years. During the plea colloquy, the defendant again voiced his desire for the self-defense instruction and his sense of being “put in a box,” but ultimately confirmed to the court that his plea was voluntary.The First District Court of Appeals reviewed the case after the defendant appealed, arguing that the trial court’s misstatements regarding Ohio’s self-defense statute and its premature indication it would not give the self-defense instruction rendered his plea involuntary and unknowing. The appellate court held that these errors did not invalidate an otherwise valid plea.The Supreme Court of Ohio affirmed, holding that when a trial court complies with Ohio Criminal Rule 11 requirements, even erroneous legal statements or pretrial rulings on ancillary matters do not render a guilty plea unknowing, unintelligent, or involuntary. The court found no violation of Rule 11 and thus upheld the conviction. View "State v. Gowdy" on Justia Law

A man was originally convicted of felony burglary for breaking into a bar in Montana and received a twenty-year prison sentence with five years suspended. After serving time and being released, he began the suspended portion of his sentence. The State later filed a petition to revoke his suspended sentence based on several alleged probation violations, including failing to register as a sex offender. While represented by counsel, he admitted to the failure-to-register allegation, and the court set a dispositional hearing to determine the consequences.The Montana Ninth Judicial District Court presided over the revocation proceeding. At the dispositional hearing, the man appeared without counsel after his attempts to retain private counsel failed and after his appointed counsel was allowed to withdraw. He requested reappointment of a public defender but none was assigned before the hearing. The court conducted no inquiry into whether he knowingly and voluntarily waived his right to counsel and proceeded with resentencing him to five years in prison. The man appealed, arguing he was denied his right to counsel at a critical stage and that he did not waive that right.The Supreme Court of the State of Montana held that the district court erred by conducting the dispositional hearing and resentencing without counsel and without a valid waiver of the right to counsel. The Court found this to be a structural error requiring automatic reversal, noting the man’s consistent efforts to obtain representation and the absence of any meaningful waiver inquiry. The Court vacated the dispositional order and remanded for a new hearing at which the man must be represented or must validly waive representation. The Court declined to resolve his request to withdraw his earlier admission, leaving it for further proceedings if appropriate. View "State v. Lambert" on Justia Law

A man was charged with felony criminal possession of dangerous drugs after being found with methamphetamine and paraphernalia following a single-vehicle crash in Sanders County, Montana. During his hospital treatment after the crash, law enforcement recovered drugs and a pipe from his clothing, and further investigation at the scene yielded additional drugs, firearms, and related items. He was prosecuted for possession of dangerous drugs, while several other related charges were dismissed prior to trial.At his jury trial in the Twentieth Judicial District Court, the defendant participated in the morning proceedings but failed to return after the lunch break. The court, over his attorney’s objection, continued the trial in his absence under Montana law, which allows the trial to proceed if a felony defendant is voluntarily absent and the crime is not punishable by death. The jury found him guilty while he was absent. He was later arrested and sentenced to five years in prison. On appeal, he argued that the trial court erred by proceeding in his absence and that his attorney was ineffective for not moving to suppress evidence found in his clothing.The Supreme Court of the State of Montana held that the district court did not err in resuming the trial in the defendant’s absence, concluding that he voluntarily absented himself and thereby waived his right to be present. The Court further held that, when voluntary absence is established, there is no need for the trial court to exercise additional due diligence to secure a defendant’s presence for the verdict. The Court also determined that the record was insufficient to review his ineffective assistance of counsel claim on direct appeal. The district court’s judgment was affirmed. View "State v. McKnight" on Justia Law

A man was indicted for unlawful possession of a firearm and ammunition by a felon after Boston police discovered a loaded pistol under the front passenger seat of a car in which he was seated. The discovery occurred shortly after a drive-by shooting in the area, though later evidence showed the car was not involved in the shooting. Video evidence and police testimony established that the man exclusively occupied the front passenger seat from the time the car arrived at a market until the stop, wore a latex glove on his right hand, and repeatedly bent toward the floor mat area where the pistol was found. No fingerprints were found on the firearm, magazine, or ammunition.The United States District Court for the District of Massachusetts denied the defendant’s motions for judgment of acquittal and for a new trial. The motions argued the evidence was insufficient to prove possession and that the government’s references to the nearby shooting were prejudicial. The court found that, viewed in the light most favorable to the government, the circumstantial evidence—including the glove, the exclusive control over the seat, and his actions toward the floor—was sufficient for a reasonable jury to find constructive possession beyond a reasonable doubt.The United States Court of Appeals for the First Circuit reviewed the case. The court held that the evidence supported the jury’s verdict of constructive possession under 18 U.S.C. § 922(g)(1). The appellate court affirmed that the district court correctly denied both the judgment of acquittal and the new trial motion, finding no miscarriage of justice or erroneous result. The court also affirmed the revocation of the defendant’s supervised release, as the evidence met the preponderance standard. The convictions and the revocation of supervised release were affirmed. View "United States v. Abercrombie" on Justia Law

A criminal defendant was charged with assault by means likely to produce great bodily injury and a related enhancement. After being arraigned in the Los Angeles County Superior Court, the defendant was remanded into custody with bail set. The preliminary hearing was scheduled for nine days after arraignment, in line with the ten-court-day deadline under California Penal Code section 859b for in-custody defendants. Due to a cyberattack, all Los Angeles County courthouses were closed on the originally scheduled hearing date, and the preliminary hearing was continued to the tenth court day. On that day, the defendant was not brought to court, and the court continued the hearing further, ordering the defendant released on his own recognizance. However, the defendant was not actually released until almost three days after the order.The trial court denied defense motions to dismiss the complaint under section 859b, reasoning that dismissal was unnecessary because the defendant had been ordered released on the tenth court day. The defendant then sought a writ of mandate from the superior court, which was denied on similar grounds. The defendant petitioned the California Court of Appeal for a writ of prohibition, which was denied by a divided panel. The California Supreme Court granted review and transferred the matter back to the Court of Appeal with instructions to reconsider.The California Court of Appeal, Second Appellate District, Division Five, held that section 859b requires dismissal of the criminal complaint when a defendant remains in custody for more than ten court days solely on that complaint and the preliminary hearing is continued beyond the statutory period, unless the defendant waives the deadline or good cause is found. The court concluded that the relevant measure is the defendant’s actual time in custody, not the date of a release order. Because the defendant was not released until after the ten-court-day period and neither waiver nor good cause was established, dismissal was mandatory. The court granted the petition for writ of prohibition and directed dismissal of the complaint. View "Benavides v. Super. Ct." on Justia Law

The case involved a defendant charged with several offenses, including possession of a firearm by a felon, possession of ammunition by a prohibited person, possession of a controlled substance with a firearm, and related drug offenses, following a 2023 arrest in Orange County. The defendant, who was on probation in three other counties, filed a motion for pretrial mental health diversion under California Penal Code section 1001.36, submitting evidence of multiple diagnosed mental disorders that were significant factors in the commission of the offenses. Expert reports and treatment records supported the defendant’s eligibility and suitability for diversion, noting his willingness to participate in treatment and the absence of any indication that he posed an unreasonable risk to public safety if treated in the community.The Superior Court of Orange County held a hearing and found that the defendant met all statutory eligibility and suitability criteria for mental health diversion. Nevertheless, the court denied the motion, exercising what it described as “residual discretion,” citing concerns about public safety, the defendant’s criminal history, substance use, a recent DUI arrest, and an alleged lack of effective court monitoring during diversion. The defendant subsequently pled guilty to most charges and was sentenced to probation and jail time, but appealed the denial of diversion.The California Court of Appeal, Fourth Appellate District, Division Three, reviewed the case. It held that while trial courts retain discretion to deny mental health diversion even when statutory criteria are met, that discretion must be exercised consistent with the statute’s principles and purposes—favoring broad application of diversion for eligible defendants. The appellate court found the lower court’s denial was based on findings unsupported by substantial evidence, speculative reasoning, and a misunderstanding of the statute’s monitoring provisions. The judgment was reversed and remanded, directing the trial court to grant diversion absent changed circumstances. View "P. v. Cabalar" on Justia Law

In this case, the defendant was involved in a violent incident that began as a fistfight between two groups at an apartment complex in Oklahoma and escalated into a gunfight. The defendant, who was present with an AK-47, fired more than twenty rounds into a crowd after shots were fired by others, resulting in the death of a bystander, Larintino Scales. Evidence at trial included various eyewitness accounts, forensic analysis, and expert testimony regarding bullet trajectories. The defendant was charged with several offenses, including voluntary manslaughter and being a felon in possession of a firearm.The United States District Court for the Eastern District of Oklahoma presided over the trial. The jury convicted the defendant of voluntary manslaughter and felon in possession, but acquitted him of other charges. The district court denied a pretrial motion alleging bad-faith destruction of potentially exculpatory evidence, allowed expert testimony on bullet trajectories, and overruled objections to the prosecutor’s closing argument regarding self-defense. The court departed upward from the Sentencing Guidelines, imposing the statutory maximum sentence of fifteen years.On appeal, the United States Court of Appeals for the Tenth Circuit reviewed the defendant’s challenges to his conviction and sentence. The court held that the district court did not clearly err in finding that the late-discovered bullet fragment lacked potentially exculpatory value. Any error in the admission of the government’s expert testimony was found to be harmless, and the expert was deemed qualified. The prosecutor’s closing statements were not found to misstate the law of self-defense. Finally, the appellate court concluded the sentence was substantively reasonable, as the district court adequately considered relevant sentencing factors and the seriousness of the offense. The Tenth Circuit affirmed the conviction and sentence. View "United States v. Holt" on Justia Law

A Michigan State Trooper conducted a traffic stop after observing a vehicle with expired registration. The passenger, Adam Santos, was identified as a convicted felon, currently on probation, and flagged in police databases as possibly armed and dangerous. During the stop, the trooper noticed Santos acting nervously and avoiding searching a cross-body bag when asked for identification. After obtaining the driver’s consent to search the vehicle, the trooper removed both occupants from the car for safety. While frisking Santos, the trooper felt a weight in the bag consistent with a firearm. A struggle ensued when the trooper attempted to open the bag, and a gun was recovered. Santos was indicted for unlawful possession of a firearm by a felon.The United States District Court for the Western District of Michigan denied Santos’s motion to suppress the gun, finding that the officer’s actions were justified by concerns for safety and that the driver voluntarily consented to the vehicle search. The court also found the frisk of Santos and the subsequent search of the bag permissible, given the reasonable suspicion and probable cause developed during the stop.On appeal, the United States Court of Appeals for the Sixth Circuit reviewed the district court’s legal conclusions de novo and its factual findings for clear error. The appellate court held that the trooper did not violate Santos’s Fourth Amendment rights. The stop was lawfully initiated, and the questions and actions taken by the officer, including the removal of both occupants and the frisk of Santos, were justified by safety concerns based on specific, articulable facts. The court affirmed the district court’s denial of the suppression motion, holding that neither the duration nor the scope of the stop nor the search of Santos’s bag was unconstitutional. View "United States v. Santos" on Justia Law

A dual citizen of the United States and Pakistan, the defendant traveled from the U.S. to Pakistan in 2009, along with four others, with the intent to join jihad in Afghanistan. Upon arrival, the group attempted to make contact with terrorist organizations and made efforts to cross into Afghanistan. Pakistani authorities arrested them in Sargodha, Pakistan, and subsequently tried and convicted them on terrorism-related offenses. The defendant served approximately ten years in a Pakistani prison. After completing his sentence, he was extradited to the United States, where he faced federal charges arising from the same underlying conduct.The United States District Court for the Eastern District of Virginia arraigned the defendant and, after he waived his Speedy Trial Act rights, considered his motion to dismiss the indictment on Sixth Amendment speedy trial grounds. The motion argued that the government’s delay in seeking his extradition and prosecution in the U.S. violated his constitutional rights. The district court denied the motion, finding that, although the length of the delay was significant, the government made reasonably diligent and good-faith efforts to secure his return, and the remaining factors weighed against finding a violation. The defendant entered a conditional guilty plea, reserving his right to appeal the speedy trial ruling.The United States Court of Appeals for the Fourth Circuit reviewed the district court’s decision, applying the four-factor balancing test from Barker v. Wingo. The appellate court agreed that only the length of the delay favored the defendant, but reasoned that the government’s efforts, the defendant’s own conduct in resisting extradition, and the absence of actual prejudice outweighed that factor. The court held there was no Sixth Amendment speedy trial violation and affirmed the conviction. View "US v. Chaudhry" on Justia Law

Law enforcement received anonymous tips in 2021 and 2022 alleging that a Wilmington resident was selling drugs and possessing firearms at his home, which also operated as an unlicensed barbershop. The tips included specific details about the individual’s activities and identifying information. After receiving the July 2022 tip, police corroborated aspects of the information through surveillance, database checks, and two traffic stops involving individuals seen leaving the residence—one was found with marijuana allegedly purchased from the suspect and another fled from police after acting suspiciously. Based on this investigation, police obtained and executed a search warrant, recovering drugs, cash, and a firearm. The individual, a previously convicted felon, was indicted on drug and firearm charges, including possession of a firearm by a person prohibited.The Superior Court of the State of Delaware denied the defendant’s motion to suppress the evidence, finding that the affidavit supporting the search warrant established probable cause through the combination of the July 2022 tip and corroborating police investigation. At trial, a police officer referred to information from the National Crime Information Center (NCIC) identifying the recovered firearm as stolen. The defense did not object to this testimony. The defendant was convicted of multiple offenses, including firearm and drug charges, and sentenced to seventeen years of incarceration.On appeal to the Supreme Court of the State of Delaware, the defendant raised claims of hearsay and Confrontation Clause violations due to the NCIC testimony, challenged the denial of his suppression motion, and argued that the statute prohibiting felons from possessing firearms was unconstitutional. The Supreme Court applied plain error review to most issues because they were not raised below, and affirmed the convictions. The Court held that there was no plain error in admitting the NCIC evidence, that the search warrant was supported by probable cause, and that the firearm prohibition statute was not plainly unconstitutional, either on its face or as applied to the defendant. The judgment of the Superior Court was affirmed. View "Johns v. State" on Justia Law