Justia Daily Opinion Summaries

Criminal Law
January 24, 2025

Table of Contents

Andrew v. White

Criminal Law

U.S. Supreme Court

Cotto v. Campbell

Constitutional Law, Criminal Law, Government & Administrative Law

U.S. Court of Appeals for the First Circuit

Humana Inc. v. Biogen, Inc.

Criminal Law, Health Law, White Collar Crime

U.S. Court of Appeals for the First Circuit

USA v. Quailes

Constitutional Law, Criminal Law

U.S. Court of Appeals for the Third Circuit

United States v. Fitzpatrick

Criminal Law

U.S. Court of Appeals for the Fourth Circuit

United States v. Jackson

Criminal Law, Health Law, Medical Malpractice, Personal Injury, White Collar Crime

U.S. Court of Appeals for the Fourth Circuit

United States v. McNeil

Civil Rights, Criminal Law

U.S. Court of Appeals for the Fourth Circuit

United States v. Shields

Criminal Law

U.S. Court of Appeals for the Fourth Circuit

United States v. Sutton

Criminal Law

U.S. Court of Appeals for the Fourth Circuit

Wells v. Fuentes

Civil Rights, Constitutional Law, Criminal Law

U.S. Court of Appeals for the Fourth Circuit

United States v. Giglio

Constitutional Law, Criminal Law

U.S. Court of Appeals for the Fifth Circuit

Uvukansi v. Guerrero

Civil Rights, Criminal Law

U.S. Court of Appeals for the Fifth Circuit

Gillman v. City of Troy

Civil Rights, Criminal Law, Personal Injury

U.S. Court of Appeals for the Sixth Circuit

ARIZONA ATTORNEYS FOR CRIMINAL JUSTICE V. MAYES

Constitutional Law, Criminal Law

U.S. Court of Appeals for the Ninth Circuit

USA V. VELAZQUEZ

Criminal Law

U.S. Court of Appeals for the Ninth Circuit

United States v. Perez

Criminal Law

U.S. Court of Appeals for the Tenth Circuit

United States v. Woodmore

Criminal Law

U.S. Court of Appeals for the Tenth Circuit

USA v. Brown

Constitutional Law, Criminal Law

U.S. Court of Appeals for the District of Columbia Circuit

USA v. Celentano

Criminal Law

U.S. Court of Appeals for the District of Columbia Circuit

USA v. Magruder

Constitutional Law, Criminal Law

U.S. Court of Appeals for the District of Columbia Circuit

P. v. Lopez

Criminal Law

Supreme Court of California

Navarro v. Cervera

Criminal Law, Family Law

California Courts of Appeal

People v. Superior Court (Vandenburgh)

Criminal Law

California Courts of Appeal

People v. Villagrana

Criminal Law

California Courts of Appeal

People v. Rodriguez-Morelos

Business Law, Criminal Law, Government & Administrative Law, Non-Profit Corporations

Colorado Supreme Court

State v. Inzitari

Constitutional Law, Criminal Law

Connecticut Supreme Court

State of Iowa v. Brown

Constitutional Law, Criminal Law

Iowa Supreme Court

State of Iowa v. Duffield

Criminal Law

Iowa Supreme Court

Commonwealth v. Montgomery

Criminal Law

Massachusetts Supreme Judicial Court

State v. Damon

Criminal Law

Montana Supreme Court

State v. Golas

Criminal Law

Montana Supreme Court

State v. Rezac

Criminal Law, Legal Ethics, Professional Malpractice & Ethics

Nebraska Supreme Court

Meiers v. NDDOT

Criminal Law, Government & Administrative Law

North Dakota Supreme Court

State v. McCleary

Criminal Law

North Dakota Supreme Court

Commonwealth v. Crosby

Criminal Law

Supreme Court of Pennsylvania

Commonwealth v. Roberts

Criminal Law

Supreme Court of Pennsylvania

Martinez v. State of Rhode Island

Criminal Law

Rhode Island Supreme Court

State v. Geter

Criminal Law

South Carolina Supreme Court

The State v. Stoots

Criminal Law

South Carolina Supreme Court

STATE v. CUARENTA

Criminal Law

Texas Court of Criminal Appeals

STATE v. HATTER

Criminal Law

Texas Court of Criminal Appeals

State v. Morgan

Criminal Law, Public Benefits

Washington Supreme Court

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Criminal Law Opinions

Andrew v. White

Court: U.S. Supreme Court

Docket: 23-6573

Opinion Date: January 21, 2025

Judge: Per Curiam

Areas of Law: Criminal Law

Brenda Andrew was convicted by an Oklahoma jury of murdering her husband, Rob Andrew, and was sentenced to death. During her trial, the prosecution introduced extensive evidence about her sex life and personal failings, which was later conceded to be irrelevant. Andrew argued in a federal habeas petition that this evidence was so prejudicial it violated the Due Process Clause.

The Oklahoma Court of Criminal Appeals (OCCA) upheld her conviction, finding some of the evidence about her extramarital affairs relevant but acknowledging that much of the other evidence was irrelevant. Despite this, the OCCA deemed the errors harmless. Two judges dissented, arguing that the prejudicial evidence undermined the fairness of the trial.

In federal court, the District Court denied relief, and the Tenth Circuit Court of Appeals affirmed, stating that Andrew failed to cite clearly established federal law. The Tenth Circuit majority acknowledged the precedent set by Payne v. Tennessee but dismissed it as a pronouncement rather than a holding. Judge Bacharach dissented, arguing that the prejudicial evidence deprived Andrew of a fair trial.

The Supreme Court of the United States reviewed the case and held that the Tenth Circuit erred in its interpretation. The Court clarified that Payne established that the Due Process Clause can protect against the introduction of unduly prejudicial evidence that renders a trial fundamentally unfair. The Court vacated the Tenth Circuit's judgment and remanded the case for further proceedings to determine if the trial court's admission of irrelevant evidence was so prejudicial as to render Andrew's trial fundamentally unfair.

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Cotto v. Campbell

Court: U.S. Court of Appeals for the First Circuit

Docket: 23-2069

Opinion Date: January 21, 2025

Judge: Julie Rikelman

Areas of Law: Constitutional Law, Criminal Law, Government & Administrative Law

Two state forensic chemists in Massachusetts tampered with drug evidence and falsified test results, affecting tens of thousands of drug cases. The Massachusetts Supreme Judicial Court (SJC) vacated over 30,000 criminal cases due to this misconduct. The SJC ruled that under the Fourteenth Amendment, affected individuals were entitled to the repayment of most funds collected due to their vacated convictions but not the automatic return of forfeited property. Instead, individuals had to file motions for relief from judgment under Rule 60(b) of the Massachusetts Rules of Civil Procedure.

The plaintiffs, whose criminal convictions were vacated, sought a federal court order for the automatic return of their forfeited property and related relief. The Commonwealth defendants moved to dismiss the complaint, arguing that the claims were barred by the Eleventh Amendment, which prohibits suits in federal court against a state by its own citizens. The United States District Court for the District of Massachusetts dismissed the complaint in part, ruling that it could not order the automatic return of forfeited property but allowed other claims to proceed under the Ex parte Young exception to the Eleventh Amendment.

The United States Court of Appeals for the First Circuit reviewed the case and concluded that the Eleventh Amendment bars all the relief sought by the plaintiffs. The court held that the plaintiffs' claims focused on a past wrong, and the Ex parte Young exception applies only to prospective relief against ongoing violations of federal law. Additionally, the state officials sued lacked the authority to enforce or change the state court procedures. The court reversed the district court's partial denial of the motion to dismiss and remanded with instructions to dismiss the case in full.

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Humana Inc. v. Biogen, Inc.

Court: U.S. Court of Appeals for the First Circuit

Docket: 24-1012

Opinion Date: January 17, 2025

Judge: Sandra Lea Lynch

Areas of Law: Criminal Law, Health Law, White Collar Crime

Humana, a health insurance company and Medicare Part C and Part D sponsor, filed a lawsuit against Biogen, a drug manufacturer, and Advanced Care Scripts, Inc. (ACS), a specialty pharmacy, in the District of Massachusetts. Humana alleged that Biogen and ACS engaged in fraudulent schemes involving three multiple sclerosis drugs, violating the civil RICO statute. Humana claimed that Biogen "seeded" the market with these drugs, funneled patients into Medicare, and indirectly funded patient copays through third-party patient-assistance programs (PAPs). Humana also alleged that ACS aided Biogen's scheme by steering patients and acting as an intermediary between Biogen and the PAPs, causing the submission of false certifications to Humana.

The district court dismissed the case, ruling that Humana lacked standing to bring RICO claims because it was an indirect purchaser and failed to plead the RICO claims with particularity as required by Federal Rule of Civil Procedure 9(b). The court found that Humana did not specify the time, place, and content of the alleged fraudulent communications and failed to detail the false certifications' language, timing, and context. Humana's motion for leave to amend the complaint was also denied.

The United States Court of Appeals for the First Circuit reviewed the case. The court affirmed the district court's dismissal, agreeing that Humana failed to meet the heightened pleading standard of Rule 9(b) for its RICO claim. The court held that Humana did not provide specific details about the fraudulent certifications or the use of mail or wire communications in furtherance of the scheme. The court also upheld the denial of leave to amend, citing undue delay and the inefficiency of seeking amendment after dismissal.

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USA v. Quailes

Court: U.S. Court of Appeals for the Third Circuit

Docket: 23-2533

Opinion Date: January 17, 2025

Judge: Cheryl Ann Krause

Areas of Law: Constitutional Law, Criminal Law

Aqudre Quailes and Ayinda Harper were separately charged with being felons in possession of a firearm in violation of 18 U.S.C. § 922(g)(1). Harper was on Pennsylvania state probation and parole when his probation officer discovered photographs of him holding firearms on social media. During a home visit, officers found a semiautomatic pistol in his residence. Harper had thirteen prior felony convictions. Quailes, on parole for one of his six prior felony convictions, was arrested for absconding from parole. Authorities found firearms and ammunition in his girlfriend’s apartment, where he had been staying.

The United States District Court for the Middle District of Pennsylvania dismissed both indictments, ruling that § 922(g)(1) was unconstitutional as applied to the defendants under the Second Amendment. The court reasoned that the defendants' status as parolees or probationers did not negate their Second Amendment rights. The Government appealed, arguing that § 922(g)(1) is constitutional as applied to state parolees and probationers.

The United States Court of Appeals for the Third Circuit reviewed the case. The court held that § 922(g)(1) is constitutional as applied to Quailes and Harper because neither had completed their criminal sentences. The court referenced its en banc decision in Range v. Attorney General, which held that § 922(g)(1) was unconstitutional for a felon who had completed his sentence, and United States v. Moore, which upheld the constitutionality of § 922(g)(1) for felons still serving their sentences. The court concluded that historical practices support disarming convicts who are still serving their sentences, including those on state parole or probation. Consequently, the Third Circuit reversed the District Court’s orders and remanded the cases for further proceedings.

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United States v. Fitzpatrick

Court: U.S. Court of Appeals for the Fourth Circuit

Docket: 24-4102

Opinion Date: January 21, 2025

Judge: Paul Niemeyer

Areas of Law: Criminal Law

Conor Fitzpatrick pleaded guilty to conspiracy to traffic in stolen personally identifying information, fraudulent solicitation of personally identifying information, and possession of child pornography. While released on bond awaiting sentencing, Fitzpatrick violated his conditions of release by secretly downloading a virtual private network and accessing the Internet without his probation officer's knowledge. At sentencing, the district court calculated Fitzpatrick’s advisory Guidelines sentencing range to be 188 to 235 months’ imprisonment but sentenced him to a 17-day time-served term of imprisonment, citing his autism spectrum disorder and youth.

The United States District Court for the Eastern District of Virginia initially handled the case. Fitzpatrick was released on bond pending sentencing, subject to several special conditions, which he violated. The district court, considering Fitzpatrick’s autism and youth, imposed a significantly reduced sentence of 17 days, arguing that the Federal Bureau of Prisons would not be able to treat Fitzpatrick’s autism spectrum disorder and that he would be vulnerable in prison.

The United States Court of Appeals for the Fourth Circuit reviewed the case. The court found that the district court abused its discretion by imposing a substantively unreasonable sentence. The Fourth Circuit held that the district court failed to adequately consider the seriousness of Fitzpatrick’s offenses, the need to promote respect for the law, to deter similar wrongdoing, and to protect the public. The court vacated the 17-day sentence and remanded the case for resentencing, emphasizing that a sentence must fulfill the purposes of punishment, deterrence, and incapacitation.

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United States v. Jackson

Court: U.S. Court of Appeals for the Fourth Circuit

Docket: 23-4467

Opinion Date: January 21, 2025

Judge: Steven Agee

Areas of Law: Criminal Law, Health Law, Medical Malpractice, Personal Injury, White Collar Crime

Dr. Anita Jackson, an otolaryngologist, was convicted of various offenses related to her private medical practice in North Carolina. She was the leading Medicare biller for balloon sinuplasty surgery, a procedure treating chronic sinusitis. Jackson reused single-use medical devices, specifically the Entellus XprESS Multi-Sinus Dilation Tool, on multiple patients without proper sterilization, leading to potential contamination. She also incentivized employees to recruit Medicare patients for the procedure, often bypassing proper medical assessments. Additionally, Jackson falsified documents and patient signatures in response to Medicare audits.

The United States District Court for the Eastern District of North Carolina convicted Jackson on all counts, including violating the Food, Drug, and Cosmetics Act (FDCA) by holding for resale adulterated medical devices, violating the federal anti-kickback statute, making materially false statements, committing aggravated identity theft, mail fraud, and conspiracy. Jackson was sentenced to twenty-five years in prison and ordered to pay over $5.7 million in restitution. She moved for a judgment of acquittal and a new trial, which the district court denied.

The United States Court of Appeals for the Fourth Circuit reviewed the case. Jackson argued that the devices were not "held for sale" under the FDCA, that her actions were protected under 21 U.S.C. § 396, and that the Government relied on a defective theory of per se adulteration. She also challenged the exclusion of certain evidence and jury instructions. The Fourth Circuit found no reversible error in the district court's rulings, holding that the devices were indeed "held for sale," that § 396 did not protect her conduct, and that the Government's theory was valid. The court also upheld the exclusion of evidence and the jury instructions. Consequently, the Fourth Circuit affirmed all of Jackson's convictions.

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United States v. McNeil

Court: U.S. Court of Appeals for the Fourth Circuit

Docket: 22-6923

Opinion Date: January 22, 2025

Judge: Pamela Harris

Areas of Law: Civil Rights, Criminal Law

In September 2018, police officers in Fayetteville, North Carolina, observed a car performing a U-turn and stopping in front of Allen Wendell McNeil's house. After a brief interaction with the car's occupants, the police conducted a traffic stop and found a small bag of marijuana on the passenger. Without a warrant, the officers then went to McNeil's house for a "knock and talk." When McNeil's children answered the door and said he was not home, the officers proceeded to the backyard, where they found McNeil in a shed and detected the smell of marijuana. This led to McNeil's detention and the subsequent search and seizure of marijuana, money, and guns from his property.

McNeil was charged with marijuana distribution and firearm possession. He pleaded guilty without a plea agreement, and the district court sentenced him to 114 months in prison. McNeil's direct appeal was affirmed by the United States Court of Appeals for the Fourth Circuit.

McNeil filed a pro se petition under 28 U.S.C. § 2255, claiming ineffective assistance of counsel for failing to file a motion to suppress evidence obtained from the warrantless search and for not pursuing a plea agreement despite his requests. The district court dismissed the petition without an evidentiary hearing, ruling that McNeil's Fourth Amendment claim was frivolous and that his statements during the Rule 11 hearing precluded his ineffective assistance claim regarding the plea agreement.

The United States Court of Appeals for the Fourth Circuit reviewed the case and concluded that McNeil's ineffective assistance claims could not be resolved on the existing record. The court held that the district court erred in dismissing McNeil's claims without an evidentiary hearing, as the facts surrounding the police officers' entry into the backyard and the plea negotiations required further factual development. The Fourth Circuit vacated the district court's judgment and remanded the case for an evidentiary hearing.

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United States v. Shields

Court: U.S. Court of Appeals for the Fourth Circuit

Docket: 23-4216

Opinion Date: January 22, 2025

Judge: Pamela Harris

Areas of Law: Criminal Law

Tytus Lamaar Shields pleaded guilty to possession of a firearm as a felon, violating 18 U.S.C. § 922(g)(1). In November 2021, law enforcement in Parkersburg, West Virginia, received information that Shields was transporting drugs. Shields, on bond for pending charges in Ohio and considered a fugitive, was arrested at his residence, where officers seized drugs, cash, and a loaded firearm. Shields admitted the firearm was his. He was charged with being a felon in possession of a firearm, knowing he had prior Ohio felony convictions, including one for drug trafficking.

The United States District Court for the Southern District of West Virginia calculated an advisory Sentencing Guidelines range of 51 to 63 months and sentenced Shields to 51 months. Shields argued for a downward variance, citing an unwarranted sentencing disparity between his case and similar cases in West Virginia, but the district court did not address this argument. The court focused on Shields’s criminal history and sustained the government’s objection to the Presentence Investigation Report, which had not applied the increased base offense level for a "controlled substance offense."

The United States Court of Appeals for the Fourth Circuit reviewed the case. The court found that the district court committed procedural error by failing to address Shields’s non-frivolous argument for a downward variance based on sentencing disparities. The appellate court held that the district court must consider and explain its reasoning regarding such arguments to allow for meaningful appellate review. Consequently, the Fourth Circuit vacated Shields’s sentence and remanded the case for resentencing, emphasizing the need for the district court to address all non-frivolous arguments presented by the defendant.

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United States v. Sutton

Court: U.S. Court of Appeals for the Fourth Circuit

Docket: 23-4029

Opinion Date: January 22, 2025

Judge: Julius Richardson

Areas of Law: Criminal Law

Margaret Ann Sutton was involved in a drug trafficking operation with Vicente Andres, a known drug dealer. Sutton initially visited Andres's house to buy and distribute drugs. Their relationship turned romantic, and they traveled together to California to purchase a large quantity of methamphetamine and marijuana. Upon returning to Virginia, they continued distributing the drugs. Sutton was actively involved in the drug sales, including a transaction with an undercover officer. During a police raid, Sutton was found with marked bills from a drug sale, and a large quantity of marijuana was discovered in a puzzle box in the house.

The United States District Court for the Eastern District of Virginia convicted Sutton in a bench trial of various federal criminal offenses, including possession with intent to distribute marijuana and use of a drug-involved premises. Sutton was sentenced to twenty-nine years in prison. She appealed her convictions and sentence, arguing insufficient evidence and procedural and substantive unreasonableness in her sentencing.

The United States Court of Appeals for the Fourth Circuit reviewed the case. The court found that there was sufficient evidence to support Sutton's convictions. The court held that Sutton constructively possessed the marijuana found in the puzzle box, as she had control over the drugs and was aware of their presence. Additionally, the court determined that Sutton actively employed the house for the purpose of drug distribution, satisfying the requirements of 21 U.S.C. § 856(a)(1). The court also found that Sutton's sentence was neither procedurally nor substantively unreasonable, noting that her sentence was below the Guidelines range and that the district court had considered her background and history.

The Fourth Circuit affirmed the district court's decision, upholding Sutton's convictions and sentence.

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Wells v. Fuentes

Court: U.S. Court of Appeals for the Fourth Circuit

Docket: 23-1638

Opinion Date: January 22, 2025

Judge: Julius Richardson

Areas of Law: Civil Rights, Constitutional Law, Criminal Law

Curtis Wells parked his car near Arlington Cemetery and was noticed by Officer Armstrong due to his animated gestures while on a phone call. Armstrong approached Wells and discovered that his car had an expired registration. Arlington County police were called, and they found that Wells did not have a driver's license and had weapons in his car. The police decided to tow Wells's car and conducted an inventory search, which revealed various weapons and tactical gear, including a ballistic plate carrier. Wells was sent home, but further investigation suggested that the plate might have been stolen from the Army. Nine days later, Wells was arrested for receiving stolen property.

In the United States District Court for the Eastern District of Virginia, Wells brought state and federal claims against various officers and entities, alleging Fourth and Fifth Amendment violations, among other claims. The district court dismissed all his claims, reasoning that the officers were protected by qualified immunity and that Wells had not plausibly alleged the necessary elements for his state tort claims.

The United States Court of Appeals for the Fourth Circuit reviewed the case and affirmed the district court's dismissal. The court held that the officers' actions were protected by qualified immunity because Wells did not have a clearly established right against the officers' conduct. The court found that the initial approach by Officer Armstrong was justified under the community-caretaking exception, the inventory search of Wells's car was conducted according to standard procedures, and Wells had consented to the safekeeping of his property. Additionally, the court held that Wells's Second Amendment claims failed because the right to public carry was not clearly established in 2020. The court also dismissed Wells's state law claims, finding that he had not plausibly alleged the necessary elements for false imprisonment or malicious prosecution.

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United States v. Giglio

Court: U.S. Court of Appeals for the Fifth Circuit

Docket: 24-60047

Opinion Date: January 23, 2025

Judge: Jennifer Elrod

Areas of Law: Constitutional Law, Criminal Law

Damion Giglio, while on supervised release for a previous felony, was arrested and convicted for violating 18 U.S.C. § 922(g)(1), the felon-in-possession statute. He appealed, arguing that the statute is unconstitutional as applied to him and that the district court erred in calculating his sentencing guideline range, entitling him to a less severe sentence.

The United States District Court for the Southern District of Mississippi denied Giglio's motion to dismiss the indictment, rejecting his constitutional challenge. Giglio pleaded guilty, and the court sentenced him to 27 months' imprisonment, noting that it would have imposed the same sentence regardless of any potential guideline calculation errors.

The United States Court of Appeals for the Fifth Circuit reviewed the case. The court held that the government could regulate Giglio’s firearm possession without violating the Second Amendment, as historical practices support disarming individuals serving criminal sentences. The court also found that any error in the sentencing guideline calculation was harmless because the district court explicitly stated it would have imposed the same sentence regardless of the guideline range.

The Fifth Circuit affirmed the district court's decision on both grounds, upholding Giglio's conviction and sentence.

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Uvukansi v. Guerrero

Court: U.S. Court of Appeals for the Fifth Circuit

Docket: 23-20435

Opinion Date: January 17, 2025

Judge: Leslie Southwick

Areas of Law: Civil Rights, Criminal Law

In 2012, three people were shot and killed outside a nightclub in Houston, Texas. Feanyichi E. Uvukansi was identified by an eyewitness, Jeresano, who picked him out of a photo array. Uvukansi was convicted of capital murder and sentenced to life without parole. At trial, Jeresano testified that he had no agreement with prosecutors regarding his testimony, but it was later revealed that he did have an agreement that could reduce his federal drug sentence in exchange for his testimony.

Uvukansi did not raise the issue of false testimony on direct appeal but did so in state habeas proceedings. The state district court found that Jeresano's testimony was false but deemed it immaterial because the jury was aware of parts of the agreement through other testimony. The Texas Court of Criminal Appeals denied Uvukansi’s application without a written order. Uvukansi then filed a Section 2254 application in federal district court, which was dismissed on the grounds that the state court's decision was not contrary to, or an unreasonable application of, clearly established Supreme Court precedent.

The United States Court of Appeals for the Fifth Circuit reviewed the case. The court held that the state district court applied the correct "reasonable likelihood" standard for materiality and did not impose a higher burden of proof on Uvukansi. The court also found that the state district court did not erroneously hold that false testimony that only affects credibility is always immaterial. The Fifth Circuit concluded that the state court's decision was not contrary to, or an unreasonable application of, clearly established Supreme Court precedent and affirmed the dismissal of Uvukansi's Section 2254 application.

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Gillman v. City of Troy

Court: U.S. Court of Appeals for the Sixth Circuit

Docket: 23-1702

Opinion Date: January 22, 2025

Judge: Rachel Bloomekatz

Areas of Law: Civil Rights, Criminal Law, Personal Injury

Megan Miller was arrested and booked into the City of Troy’s pretrial detention facility, where she informed staff that she had been heavily using heroin and expected to go into withdrawal. Over the next two and a half days, Miller vomited continually. On the third day, she was found unconscious and unresponsive in her cell and was pronounced dead shortly after. Despite her continual vomiting, no jail official sought medical care for her, including Julie Green-Hernandez, who was responsible for monitoring detainees on the day of Miller’s death. Miller’s husband sued Green-Hernandez, claiming she violated Miller’s Fourteenth Amendment right to adequate pretrial medical care and acted with gross negligence under Michigan state law.

The United States District Court for the Eastern District of Michigan denied Green-Hernandez’s motion for summary judgment, concluding she was not entitled to qualified immunity on the Fourteenth Amendment claim or state law immunity on the negligence claim. The court found that there were disputes of material fact regarding whether Green-Hernandez was deliberately indifferent to Miller’s serious medical needs and whether her conduct amounted to gross negligence.

The United States Court of Appeals for the Sixth Circuit reviewed the case. The court dismissed Green-Hernandez’s appeal regarding qualified immunity due to lack of jurisdiction, as her arguments were based on factual disputes rather than purely legal questions. However, the court reversed the district court’s denial of Michigan governmental immunity. The Sixth Circuit held that while Green-Hernandez’s conduct could be considered grossly negligent, it was not the single most proximate cause of Miller’s death. The court concluded that Miller’s ingestion of fentanyl was the most immediate, efficient, and direct cause of her death, entitling Green-Hernandez to state law immunity. The case was remanded for further proceedings consistent with this opinion.

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ARIZONA ATTORNEYS FOR CRIMINAL JUSTICE V. MAYES

Court: U.S. Court of Appeals for the Ninth Circuit

Docket: 22-16729

Opinion Date: January 23, 2025

Judge: Anthony Johnstone

Areas of Law: Constitutional Law, Criminal Law

The case involves a challenge to an Arizona law that requires criminal defense attorneys and their agents to initiate any contact with crime victims through the prosecutor’s office. The plaintiffs, a group of criminal defense attorneys and their association, argue that this law violates the First Amendment's Speech Clause by restricting their ability to communicate directly with victims.

The United States District Court for the District of Arizona initially dismissed the case for lack of standing, but the Ninth Circuit Court of Appeals reversed that decision, allowing the case to proceed. On remand, the district court held a bench trial and concluded that the law was unconstitutional on its face, issuing a permanent injunction against its enforcement. The district court found that the law's requirement for defense attorneys to communicate through the prosecutor's office was a content- and viewpoint-based regulation of speech.

The United States Court of Appeals for the Ninth Circuit reviewed the case and reversed the district court’s judgment. The Ninth Circuit held that the plaintiffs' facial challenge failed because they did not challenge the law's primary application to victim-interview requests, which remain regulated under a similar Arizona Rule of Criminal Procedure. The court noted that the unchallenged applications of the law, which include requests for victim interviews, are substantial and legitimate. Therefore, the challenged applications related to non-interview contacts are not substantial enough to render the entire statute unconstitutional.

The Ninth Circuit vacated the permanent injunction and remanded the case for entry of judgment in favor of the defendants, concluding that the facial challenge to the Victim Contact Limit, as framed by the plaintiffs, must fail.

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USA V. VELAZQUEZ

Court: U.S. Court of Appeals for the Ninth Circuit

Docket: 22-50239

Opinion Date: January 21, 2025

Judge: James Selna

Areas of Law: Criminal Law

Alfred Velazquez, a U.S. citizen residing in Tijuana, was stopped by U.S. Customs and Border Protection Officer Sean Hanlon while entering the United States from Mexico. Hanlon noticed Velazquez's nervous behavior and inconsistencies in his story about his destination. A cursory search of Velazquez's vehicle, a red Pontiac Firebird, revealed signs of tampering around the engine. A canine inspection led to the discovery of 4.53 pounds of fentanyl and heroin hidden in the vehicle. Velazquez was arrested, and the drugs were seized.

The Government charged Velazquez with importing a mixture containing fentanyl under 21 U.S.C. §§ 952 and 960. At his first trial, Velazquez was convicted, but the conviction was reversed due to a prosecutorial error. A second trial ended in a mistrial with a hung jury. In the third trial, the district court admitted testimony from a Homeland Security Investigations Special Agent about the retail value of the seized fentanyl, which ranged from $405,888 to $608,832. Velazquez was found guilty, and the court sentenced him to 139 months in custody and 5 years of supervised release. Velazquez appealed the admission of the retail value testimony.

The United States Court of Appeals for the Ninth Circuit reviewed the case. The court held that district courts do not abuse their discretion when admitting evidence of the retail value of narcotics in importation cases if the evidence is relevant, probative, and not unfairly prejudicial under the Federal Rules of Evidence. The court found that the retail value of the fentanyl was relevant to Velazquez's knowledge of the drugs and that its probative value was not substantially outweighed by any prejudicial effect. The Ninth Circuit affirmed the district court's decision to admit the testimony and upheld Velazquez's conviction.

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United States v. Perez

Court: U.S. Court of Appeals for the Tenth Circuit

Docket: 24-3015

Opinion Date: January 17, 2025

Judge: Gregory Alan Phillips

Areas of Law: Criminal Law

Law enforcement identified the defendant as a supplier of methamphetamine and fentanyl in a drug-trafficking conspiracy in Kansas City. After seizing three pounds of methamphetamine from a car en route to the defendant, DEA agents enlisted the driver to continue the delivery to the defendant. The defendant was arrested upon arrival to collect the drugs. During custody, the defendant made incriminating statements and consented to a search of his cell phone. He later moved to suppress these statements and the phone's contents.

The United States District Court for the District of Kansas denied the suppression motions. The court ruled that the defendant's pre-Miranda statement about his cell phone number was admissible under the inevitable-discovery doctrine. It also found that the defendant voluntarily and knowingly waived his Miranda rights and that his post-Miranda statements were not coerced. The court concluded that the defendant's consent to the cell phone search was voluntary.

The United States Court of Appeals for the Tenth Circuit reviewed the case. The court affirmed the district court's decision, agreeing that the inevitable-discovery doctrine applied to the pre-Miranda statement. It found that the defendant voluntarily and knowingly waived his Miranda rights, and his statements were not coerced. The court also held that the defendant's consent to the cell phone search was voluntary. The Tenth Circuit concluded that the totality of the circumstances supported the district court's findings and affirmed the denial of suppression.

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United States v. Woodmore

Court: U.S. Court of Appeals for the Tenth Circuit

Docket: 23-7044

Opinion Date: January 22, 2025

Judge: Jerome Holmes

Areas of Law: Criminal Law

The case involves Calvin Woodmore, who was convicted for his role in a methamphetamine-trafficking ring in eastern Oklahoma. Woodmore was found guilty of conspiracy to commit drug trafficking, conspiracy to commit money laundering, and money laundering. He appealed his convictions and sentence, arguing that the district court made several errors during his trial and sentencing.

In the lower court, the United States District Court for the Eastern District of Oklahoma handled the case. Woodmore was convicted by a jury on all counts. He then moved for a judgment of acquittal, arguing that the government had not provided sufficient evidence to support the money laundering charges. The district court denied his motion and sentenced him to 324 months in prison for the drug trafficking conspiracy and 240 months for the money laundering charges, to be served concurrently.

The United States Court of Appeals for the Tenth Circuit reviewed the case. Woodmore raised several issues on appeal, including the district court's failure to properly instruct the jury on the definition of "methamphetamine (actual)" and the right of attorneys to interview witnesses. He also challenged the sufficiency of the evidence supporting his money laundering convictions and the district court's calculation of his sentence.

The Tenth Circuit affirmed the district court's decisions. The appellate court found that the jury instructions were adequate and that the evidence presented at trial was sufficient to support Woodmore's convictions. The court also upheld the district court's calculation of the drug quantity attributable to Woodmore and the application of sentencing enhancements. Consequently, the Tenth Circuit affirmed Woodmore's convictions and sentence.

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USA v. Brown

Court: U.S. Court of Appeals for the District of Columbia Circuit

Docket: 23-3074

Opinion Date: January 17, 2025

Judge: Patricia Ann Millett

Areas of Law: Constitutional Law, Criminal Law

Jeffrey Brown, Markus Maly, and Peter Schwartz were tried and convicted by a jury for assaulting police officers on the Capitol grounds on January 6, 2021. They traveled separately to Washington, D.C., and participated in the riot following then-President Trump’s rally. Evidence showed that Maly and Schwartz assaulted officers on the Lower West Terrace, with Schwartz throwing a chair and both using pepper spray. All three later entered the Tunnel, where they used pepper spray against officers and attempted to push through the police line.

The United States District Court for the District of Columbia denied Schwartz’s motions to suppress evidence obtained from his cellphone and to sever the trials. The court found that the FBI had compelled Schwartz to unlock his phone but ruled that this act was not testimonial. The jury convicted all three defendants on all counts, and the district court sentenced Schwartz to 170 months, Maly to 72 months, and Brown to 54 months.

The United States Court of Appeals for the District of Columbia Circuit reviewed the case. The court affirmed Brown’s and Maly’s convictions and Brown’s sentence. It vacated Schwartz’s conviction on the 18 U.S.C. § 1512(c)(2) charge and remanded for resentencing. The court also held that compelling Schwartz to unlock his cellphone violated the Fifth Amendment and remanded to the district court to determine which, if any, of Schwartz’s counts of conviction must be vacated due to this error. The court found sufficient evidence to support the jury’s findings that the defendants used pepper spray and, in Schwartz’s case, a chair as deadly or dangerous weapons. The court also upheld the district court’s refusal to give a special unanimity instruction for Maly’s Section 111 counts and found no abuse of discretion in Brown’s sentencing.

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USA v. Celentano

Court: U.S. Court of Appeals for the District of Columbia Circuit

Docket: 24-3016

Opinion Date: January 21, 2025

Judge: Judith Rogers

Areas of Law: Criminal Law

On January 6, 2021, Ralph Joseph Celentano, III participated in the events at the United States Capitol, where he was involved in altercations with law enforcement officers. He was convicted by a jury on six counts related to his conduct that day, including forcibly shoving Officer Kenrick Ellis off a ledge. Celentano challenged his convictions on several grounds, including errors in jury instructions and sentencing.

The United States District Court for the District of Columbia convicted Celentano on six counts and acquitted him on one count. The district court sentenced him to 78 months of imprisonment on Count One, with concurrent sentences on the other counts, and 36 months of supervised release on Counts One and Two. Celentano appealed, arguing that the district court erred in its jury instructions and sentencing calculations.

The United States Court of Appeals for the District of Columbia Circuit reviewed the case. The court found that the district court's jury instruction on the defense of another was erroneous because it required the jury to consider the use of force from the perspective of a reasonable law enforcement officer rather than from Celentano's perspective. This error was not harmless regarding Count One, leading the court to vacate Celentano's conviction on that count. However, the error was deemed harmless for Counts Two, Five, and Six due to overwhelming evidence of Celentano's other violent acts.

The court also addressed Celentano's Double Jeopardy challenge, noting that it was no longer a live issue due to the vacatur of Count One. Additionally, the court rejected Celentano's challenge to the jury instructions on Counts Three, Four, and Five, citing precedent that the government only needed to prove Celentano knew he was in a restricted area.

Finally, the court vacated Celentano's sentence due to several errors in the Sentencing Guidelines calculation and remanded the case for resentencing. The case was remanded to the district court for further proceedings, except for Count Seven.

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USA v. Magruder

Court: U.S. Court of Appeals for the District of Columbia Circuit

Docket: 22-3025

Opinion Date: January 21, 2025

Judge: Karen Henderson

Areas of Law: Constitutional Law, Criminal Law

In October 2019, Edward Magruder pleaded guilty to possession with intent to distribute more than a kilogram of heroin. He later sought to withdraw his plea, arguing that the district court erred by requiring him to assert his innocence to withdraw the plea and that his plea was tainted due to ineffective assistance of counsel. The investigation leading to his arrest involved the FBI and Colombian National Police, who identified Magruder through wiretaps and geolocation data as part of a drug-trafficking conspiracy. Magruder was arrested in June 2019 after being observed traveling between D.C. and New York with heroin in his backpack.

The United States District Court for the District of Columbia denied Magruder's motions to withdraw his plea. The court found that Magruder failed to assert a viable claim of innocence and that his plea was not tainted by ineffective assistance of counsel. Magruder's new counsel filed multiple motions to withdraw the plea, all of which were denied. The district court sentenced Magruder to 180 months of imprisonment followed by 60 months of supervised release.

The United States Court of Appeals for the District of Columbia Circuit reviewed the case. The court held that the district court did not abuse its discretion in denying Magruder's motion to withdraw his guilty plea. The appellate court found that even if the district court erred in requiring an assertion of innocence, the error was harmless because Magruder's Fourth Amendment claims were meritless. The court concluded that Magruder's counsel was not ineffective for failing to raise these claims, as the search of Magruder's backpack was lawful and the evidence obtained from the Louisiana search warrant was admissible under the good-faith exception. The judgment of the district court was affirmed.

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P. v. Lopez

Court: Supreme Court of California

Docket: S281488

Opinion Date: January 23, 2025

Judge: Goodwin Liu

Areas of Law: Criminal Law

In October 2014, Oscar Lopez and Sergio Vidrio stopped their car next to Nestor M. and Noel A.'s car. After a brief exchange, Lopez and Vidrio fired multiple shots, killing Nestor and injuring Noel. Lopez was convicted of first-degree murder, attempted premeditated murder, shooting at an occupied vehicle, and possession of a firearm by a felon. The jury found that Lopez committed the crimes for the benefit of a criminal street gang and used a firearm. Lopez was sentenced to 141 years to life in prison.

Lopez appealed, and the Court of Appeal modified his sentence and conditionally reversed the judgment, remanding the case to the trial court for resentencing under Senate Bill Nos. 620 and 1393. While awaiting resentencing, Assembly Bill 333, which amended the gang enhancement statute, was enacted. The trial court declined to apply Assembly Bill 333 retroactively, resentencing Lopez to 101 years to life. Lopez appealed again, and the Court of Appeal held that the judgment was nonfinal for Estrada purposes but that the superior court lacked jurisdiction to apply Assembly Bill 333.

The Supreme Court of California reviewed the case and held that Lopez was entitled to the retroactive application of Assembly Bill 333 because his judgment was not final for Estrada purposes. The court clarified that a criminal case is not final until the entire prosecution, including sentencing, is complete. The court reversed the judgment below and remanded for further proceedings consistent with its opinion, allowing Lopez to renew his arguments for resentencing under Senate Bill Nos. 567 and 81.

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Navarro v. Cervera

Court: California Courts of Appeal

Docket: A169830(First Appellate District)

Opinion Date: January 22, 2025

Judge: Ioana Petrou

Areas of Law: Criminal Law, Family Law

Ashley Navarro and Goretti Cervera were in a relationship for approximately eight years. During and after their relationship, Cervera struggled with mental health issues, including borderline personality disorder, general anxiety, and major depressive disorder. In July 2018, after their breakup, Cervera attempted to confront Navarro at her workplace, leading to a violent incident where Cervera was found with a large kitchen knife and admitted to intending to kill Navarro. Navarro obtained an emergency protective order and a five-year domestic violence restraining order (DVRO) against Cervera. Cervera violated the DVRO in 2019 by contacting Navarro via email and text, leading Navarro to obtain a three-year criminal protective order.

The Alameda County Superior Court initially issued the DVRO based on the 2018 incident, finding Navarro had a reasonable apprehension of physical harm. In May 2023, Navarro sought a permanent renewal of the DVRO, citing ongoing fear of harm due to Cervera's mental health issues and past behavior. Cervera opposed the renewal, claiming her mental health had stabilized and she had not contacted Navarro in four years. The trial court denied the renewal request, finding Navarro's fear of future abuse unreasonable and noting Cervera's improved mental health and lack of recent contact.

The California Court of Appeal, First Appellate District, Division Three, reviewed the case and found that the trial court abused its discretion. The appellate court held that the facts of the 2018 incident, combined with Cervera's violations of the DVRO, established a reasonable apprehension of future abuse. The court reversed the trial court's decision and directed it to grant the renewal request, determining whether the DVRO should be renewed for five or more years, or permanently.

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People v. Superior Court (Vandenburgh)

Court: California Courts of Appeal

Docket: A170818(First Appellate District)

Opinion Date: January 23, 2025

Judge: Alison M. Tucher

Areas of Law: Criminal Law

Mark Vandenburgh was found with illegal drugs and money on two occasions, leading to criminal charges and civil forfeiture proceedings. In the first instance, he was found with methamphetamine and $2,795, and in the second, with methamphetamine, heroin, a short-barreled shotgun, and cash totaling $1,808. The district attorney initiated forfeiture proceedings for the money in both cases. Vandenburgh was convicted in one case and the other was dismissed. Over two years later, he filed a motion to compel the return of the seized money, arguing improper notice of forfeiture proceedings.

The Solano County Superior Court granted Vandenburgh’s motion, ruling that the district attorney did not properly follow statutory procedures for giving notice of the seizures. The People moved for reconsideration, which was denied, and subsequently petitioned for a writ of mandate.

The California Court of Appeal, First Appellate District, Division Three, reviewed the case. The court found that the district attorney’s office had properly initiated the forfeiture proceedings and that the police officers served the notices on behalf of the district attorney, not on their own behalf. The court concluded that the procedures followed by the district attorney’s office satisfied the statutory requirements for initiating and providing notice of forfeiture proceedings.

The court granted the People’s petition for a writ of mandate, directing the trial court to vacate its order granting Vandenburgh’s motion and to issue a new order denying it. The stay issued on July 9, 2024, was dissolved upon issuance of the remittitur.

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People v. Villagrana

Court: California Courts of Appeal

Docket: B331439A(Second Appellate District)

Opinion Date: January 21, 2025

Judge: Hernaldo Baltodano

Areas of Law: Criminal Law

In June 2013, Los Angeles Sheriff’s deputies responded to a drive-by shooting where they found a man with multiple gunshot wounds who later died at the hospital. Javier Villagrana and his cousin, Jaime Chavez, were charged with the murder of Juan Vasquez, with gang and firearm enhancements. Villagrana pleaded no contest to voluntary manslaughter and admitted to gang and firearm use allegations, resulting in a 26-year prison sentence. Chavez also pleaded no contest to voluntary manslaughter and admitted the gang enhancement but did not admit to using a firearm.

Villagrana later filed a petition for resentencing under Penal Code section 1172.6, arguing he could not be convicted of murder under the amended laws. The trial court found he established a prima facie case and issued an order to show cause. After an evidentiary hearing, the trial court denied the petition, concluding Villagrana was ineligible for resentencing as he was the actual killer or a direct aider and abettor to the murder.

The California Court of Appeal, Second Appellate District, reviewed the case and affirmed the trial court’s decision. The court held that substantial evidence supported the trial court’s finding that Villagrana was ineligible for resentencing. The court noted that Villagrana’s plea and admissions, including his use of a firearm and the gang-related nature of the crime, were sufficient to establish his guilt beyond a reasonable doubt as either the actual shooter or a direct aider and abettor. The court rejected the argument that the trial court applied an erroneous standard of proof, affirming that the People had proven Villagrana’s guilt beyond a reasonable doubt under the new law.

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People v. Rodriguez-Morelos

Court: Colorado Supreme Court

Docket: 22SC982

Opinion Date: January 21, 2025

Judge: Melissa Hart

Areas of Law: Business Law, Criminal Law, Government & Administrative Law, Non-Profit Corporations

In 2015, Jesus Rodriguez-Morelos began offering Certified Nursing Assistant (CNA) classes, falsely claiming they were affiliated with the nonprofit organization United with Migrants. He charged students for these classes, which were not state-approved, and used the nonprofit's name and tax-exempt document without authorization. Complaints about the classes led to an investigation by the Colorado Department of Regulatory Agencies (DORA), revealing that Rodriguez-Morelos was unlawfully receiving money for the unapproved classes.

Rodriguez-Morelos was charged with several crimes, including identity theft under section 18-5-902(1)(a), C.R.S. (2024). A jury convicted him on all charges. On appeal, the Colorado Court of Appeals affirmed the theft and criminal impersonation convictions but vacated the identity theft conviction. The court concluded that the identity theft statute's definition of "personal identifying information" pertains to individuals, not organizations, and thus did not apply to Rodriguez-Morelos's use of the nonprofit's name and document.

The Supreme Court of Colorado reviewed the case and affirmed the Court of Appeals' decision. The court held that the identity theft statute's reference to "personal identifying information" applies only to information concerning single, identified human beings, not organizations. Therefore, Rodriguez-Morelos's actions did not constitute identity theft under the statute.

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State v. Inzitari

Court: Connecticut Supreme Court

Docket: SC21008

Opinion Date: January 21, 2025

Judge: Nora Dannehy

Areas of Law: Constitutional Law, Criminal Law

The defendant was convicted of possessing child pornography in the first degree, which requires proof of possessing fifty or more images of child pornography. The New Britain Police Department obtained a search warrant for the defendant’s cell phone, which revealed images of suspected child pornography. The state introduced fifty-seven images at trial, and the defendant was found guilty by a jury.

The defendant appealed, arguing that thirteen of the images did not constitute child pornography as they depicted mere nudity, which is protected under the First Amendment. He also contended that the trial court improperly instructed the jury on the Dost factors, which are used to determine whether an image depicts a lascivious exhibition of the genitals or pubic area. The trial court had instructed the jury that it could consider these factors but was not obligated to do so.

The Connecticut Supreme Court reviewed the case and concluded that at least eleven of the thirteen challenged images depicted a lascivious exhibition of the genitals or pubic area, thus constituting child pornography. The court also determined that the first five Dost factors are helpful in assessing whether a depiction is lascivious but should not be used to define the term. The sixth Dost factor, which considers whether the image is intended to elicit a sexual response in the viewer, should not be used in possession cases as it introduces a subjective element.

The court found that the trial court’s instruction on the Dost factors, including the sixth factor, did not mislead the jury. The court also held that a specific unanimity instruction was not required, as the different images and categories of sexually explicit conduct are merely means of proving the elements of the offense. The court affirmed the trial court’s decision to admit exhibits showing file names of deleted images associated with the defendant’s email address, as they were probative of the defendant’s knowledge and possession of child pornography. The judgment was affirmed.

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State of Iowa v. Brown

Court: Iowa Supreme Court

Docket: 22-1188

Opinion Date: January 17, 2025

Judge: Christopher McDonald

Areas of Law: Constitutional Law, Criminal Law

Lukouxs Brown was charged with first-degree murder after allegedly killing a coworker. Before his arraignment, his counsel observed signs of mental illness, including hearing voices and a history of schizophrenia. The district court found probable cause to believe Brown was not competent to stand trial and ordered a psychiatric evaluation. Dr. Arnold Andersen diagnosed Brown with a schizophrenia-like disorder and substance abuse disorders, concluding he was not competent but could potentially be restored to competency. Brown was committed to the Iowa Medical and Classification Center (IMCC) for treatment.

After eight months of treatment, Dr. Andersen reported that Brown remained incompetent and unlikely to be restored to competency within a reasonable time. The district court, however, allowed the State to obtain a separate psychiatric evaluation, which concluded that Brown was competent. The district court found Brown competent to stand trial and reinstated the criminal proceedings. Brown filed an interlocutory appeal, arguing the district court erred in its competency determination and in allowing the State to obtain a separate evaluation.

The Iowa Court of Appeals reviewed the case de novo, found Brown was not competent, and remanded the case for further treatment. The State sought further review, challenging the standard of review and the district court's decision to allow a separate evaluation. The Iowa Supreme Court reaffirmed the de novo standard of review for competency determinations, emphasizing the protection of constitutional rights. The court also held that Iowa Code does not permit separate psychiatric evaluations at the dispositional phase of competency proceedings. The court vacated the Court of Appeals decision, reversed the district court order, and remanded the case for further proceedings consistent with its opinion.

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State of Iowa v. Duffield

Court: Iowa Supreme Court

Docket: 23-0786

Opinion Date: January 17, 2025

Judge: Christopher McDonald

Areas of Law: Criminal Law

Isaiah Duffield was required to register as a sex offender due to a juvenile adjudication for sexual abuse. In April 2022, he was charged with sexual abuse in the third degree, second or subsequent offense, and failure to comply with the sex offender registry. After the charges were severed and amended, Duffield entered a guilty plea to the lesser offense of failure to register, an aggravated misdemeanor. The district court sentenced him to a term of incarceration not to exceed two years and a fine of $1,025, which was suspended. The court ordered the sentence to be served consecutively to a sentence in a separate sexual abuse case.

Duffield appealed to the Iowa Court of Appeals, arguing that the district court abused its discretion in imposing the $1,025 fine and failed to state its reasons for imposing consecutive sentences. The court of appeals upheld the fine, reasoning it was within the statutory range and Duffield did not establish any irregularity. However, the court agreed that the district court erred in failing to state reasons for consecutive sentences and remanded the case to a different judge to decide whether the sentences should be served concurrently or consecutively.

The Iowa Supreme Court reviewed the case and focused on the consecutive sentencing issue. The court held that the district court erred in failing to state its reasons for imposing consecutive sentences. The court vacated Duffield’s sentence and remanded the case for a plenary resentencing hearing, emphasizing that the resentencing should not be limited to the consecutive sentencing issue alone. The court also concluded that resentencing before a different judge was not required, as there was no taint in the sentencing process. The decision of the court of appeals was vacated, the conviction was affirmed, the sentence was vacated, and the case was remanded for resentencing.

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Commonwealth v. Montgomery

Court: Massachusetts Supreme Judicial Court

Docket: SJC-13594

Opinion Date: January 17, 2025

Judge: Elizabeth Dewar

Areas of Law: Criminal Law

The defendant was convicted of second-degree murder for the killing of Paul Finegan at a backyard birthday party in Springfield. The defendant arrived at the party, where the victim, who was uninvited, became upset upon seeing him. After a brief argument, the defendant shot the victim in the head and fled the scene. The victim was unarmed, and the defendant did not testify at trial. The defense argued that the eyewitnesses were not credible and had been pressured by the police.

The case was initially tried in the Superior Court, where the defendant was found guilty of second-degree murder. The defendant filed a motion for a new trial, arguing that a voir dire question asked by the prosecutor during jury selection was improper and deprived him of an impartial jury. The trial judge denied the motion, and the Appeals Court affirmed the conviction and the denial of the motion for a new trial.

The Supreme Judicial Court of Massachusetts reviewed the case. The court found that the prosecutor's voir dire question, which asked prospective jurors if they could convict the defendant based on eyewitness testimony without forensic evidence, was improper. However, the court concluded that this error did not create a substantial risk of a miscarriage of justice. The court noted that the evidence against the defendant was overwhelming, and the jury had been properly instructed on the burden of proof and the evaluation of eyewitness testimony. The court affirmed the defendant's conviction and the order denying his motion for a new trial.

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State v. Damon

Court: Montana Supreme Court

Citation: 2025 MT 12

Opinion Date: January 22, 2025

Judge: Beth Baker

Areas of Law: Criminal Law

David Damon pleaded guilty to felony incest and was sentenced to fifty years in prison with ten years suspended. His parole eligibility was contingent upon completing Phases I and II of the prison's sex offender treatment program. After ten years without being enrolled in Phase II, Damon filed a motion to modify his sentence to allow participation in an external residential treatment program. The Eighth Judicial District Court denied his motion, citing a lack of authority to modify the judgment. Damon appealed.

The Cascade County District Court initially sentenced Damon in February 2014 after he pleaded guilty to one count of felony incest, dismissing two other charges as part of a plea agreement. Damon was designated a Tier II sex offender and required to complete specific treatment phases before being eligible for parole. In 2017, the Montana Legislature mandated the Department of Corrections (DOC) to adopt evidence-based programs, leading to the replacement of the SABER program with the SO-ICPM program in 2023. Damon argued that the elimination of the SABER program left him unable to meet his sentence requirements and sought modification to attend a residential program.

The Supreme Court of the State of Montana reviewed the case and affirmed the lower court's decision. The court held that the District Court lacked the legal authority to modify Damon's sentence, as the DOC's programming changes did not render the sentence factually erroneous. The court noted that the new SO-ICPM program provided equivalent treatment to the SABER program, allowing Damon to fulfill his sentence requirements. The court also clarified that any request for placement in a residential treatment program must be made through the DOC, not the court. Thus, the District Court's denial of Damon's motion was upheld.

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State v. Golas

Court: Montana Supreme Court

Citation: 2025 MT 11

Opinion Date: January 22, 2025

Judge: Laurie McKinnon

Areas of Law: Criminal Law

Ronald L. Golas was charged with driving under the influence of alcohol (fourth or subsequent offense), operating a motor vehicle while his license was suspended, and failure to carry proof of insurance. These charges stemmed from a one-vehicle crash where Golas was found with an open can of beer and a high alcohol concentration. He had prior DUI convictions and a suspended license. Golas pleaded not guilty and was released on bail with conditions. However, he failed to appear at pretrial conferences and had several positive alcohol tests, leading to a motion to revoke his release and the issuance of a bench warrant.

The trial date was rescheduled multiple times due to various issues, including Golas's failure to resolve the outstanding warrant. Eventually, Golas was taken into custody, and a new trial date was set. He filed a motion to dismiss for lack of a speedy trial, which was denied. Golas later requested a change-of-plea hearing and entered a plea agreement, pleading guilty to the felony DUI charge in exchange for the dismissal of the other charges. He was sentenced to 24 months in the Department of Corrections and a consecutive 5-year suspended term in the Montana State Prison.

The Montana Supreme Court reviewed the case and held that Golas waived his right to appeal the denial of his motion to dismiss for lack of a speedy trial by not specifically reserving this right in his plea agreement. The court found that Golas's plea was voluntary and intelligent, and there were no jurisdictional defects. Consequently, the court affirmed the District Court's decision.

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State v. Rezac

Court: Nebraska Supreme Court

Citation: 318 Neb. 352

Opinion Date: January 17, 2025

Judge: Jeffrey Funke

Areas of Law: Criminal Law, Legal Ethics, Professional Malpractice & Ethics

Karsen H. Rezac was involved in a vehicular collision on December 23, 2022, in Lincoln, Nebraska, which resulted in the shooting death of Kupo Mleya. Rezac, who was identified as a suspect based on vehicle debris and witness reports, admitted to firing shots at Mleya's vehicle after the collision. Rezac was charged with second-degree murder and use of a firearm to commit a felony. He later pled no contest to second-degree murder as part of a plea agreement, and the firearm charge was dropped.

The district court for Lancaster County, Nebraska, denied Rezac's motion to continue his sentencing hearing, which he requested to allow more time to gather and review his mental health records. The court proceeded with the sentencing, considering the presentence investigation report and supplemental items. Rezac was sentenced to 60 years to life imprisonment. Rezac appealed, arguing that the court abused its discretion in denying the continuance and imposing an excessive sentence, and that his trial counsel was ineffective in several respects.

The Nebraska Supreme Court reviewed the case and found that Rezac forfeited his argument regarding the denial of the continuance by failing to raise the issue at the sentencing hearing. The court also found no abuse of discretion in the sentencing, as the district court had considered the relevant mitigating factors. The court rejected Rezac's claims of ineffective assistance of counsel related to the failure to move to suppress his statement to law enforcement and the failure to explain the penalties for second-degree murder, finding that the record refuted these claims.

However, the court found the record insufficient to address Rezac's claims that his trial counsel was ineffective for advising him that self-defense was not a viable argument, failing to explain the difference between second-degree murder and involuntary manslaughter, and failing to provide his mental health records to probation or the court. The court affirmed Rezac's conviction and sentence but noted that these claims of ineffective assistance of counsel could not be resolved on direct appeal due to the insufficient record.

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Meiers v. NDDOT

Court: North Dakota Supreme Court

Citation: 2025 ND 21

Opinion Date: January 23, 2025

Judge: Douglas Bahr

Areas of Law: Criminal Law, Government & Administrative Law

On December 19, 2023, Lee Meiers was arrested for driving under the influence. The arresting officer read Meiers the implied consent advisory and conducted a chemical breath test, which showed an alcohol concentration above the legal limit. The officer completed and certified a report and notice form, printed and signed the test record and checklist, and provided copies to Meiers and the North Dakota Department of Transportation (NDDOT). However, the officer did not certify the test record and checklist before forwarding it to the NDDOT.

Meiers requested an administrative hearing, where he objected to the admission of the uncertified test record and checklist, arguing that it was not certified as required by N.D.C.C. § 39-20-03.1, and thus the NDDOT lacked authority to suspend his driving privileges. The hearing officer overruled the objection, admitted the test record and checklist, and suspended Meiers’s driving privileges for 180 days. Meiers appealed to the District Court of Mountrail County, which reversed the hearing officer’s decision, concluding that a certified copy of the test record and checklist was required to invoke the NDDOT’s authority.

The North Dakota Supreme Court reviewed the case and reversed the district court’s judgment. The Supreme Court held that the requirement in N.D.C.C. § 39-20-03.1(4) for the test record and checklist to be certified is not a basic and mandatory provision that impacts the NDDOT’s authority to suspend a driver’s privileges. The court emphasized that the certification requirement is for evidentiary purposes and can be accomplished through other means. Therefore, the NDDOT had the authority to suspend Meiers’s driving privileges despite the lack of certification on the test record and checklist. The Supreme Court reinstated the NDDOT’s decision to suspend Meiers’s driving privileges.

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State v. McCleary

Court: North Dakota Supreme Court

Citation: 2025 ND 24

Opinion Date: January 23, 2025

Judge: Lisa Fair McEvers

Areas of Law: Criminal Law

Joshua McCleary was charged with multiple counts of theft, burglary, criminal mischief, and conspiracy related to a series of thefts between December 2020 and January 2021. At the time of these charges, McCleary was already incarcerated for previous convictions. He filed a request for a speedy trial under the Uniform Mandatory Disposition of Detainers Act (UMDDA), which requires a trial within ninety days unless good cause is shown for a delay. McCleary was paroled but remained in custody due to failure to post bail on the new charges.

The District Court of Barnes County denied McCleary's motions to dismiss, stating that the UMDDA's ninety-day period no longer applied once he was released from the state penitentiary on parole. McCleary conditionally pled guilty to seven counts, reserving the right to appeal the denial of his motions to dismiss. The court entered a judgment noting the conditional nature of the pleas.

The North Dakota Supreme Court reviewed the case. McCleary argued that his case should have been brought to trial within the ninety-day period under the UMDDA because he remained in state custody. The court held that the UMDDA did not apply once McCleary was paroled, as he was no longer serving a prison sentence but was a detainee due to not posting bail. The court also found that McCleary waived any procedural defects regarding the habitual offender status by stipulating that the statutory requirements were met. Lastly, the court determined that the judgment did not need correction to specify the conditional nature of the plea, as it was clear on the face of the judgment.

The North Dakota Supreme Court affirmed the criminal judgment.

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Commonwealth v. Crosby

Court: Supreme Court of Pennsylvania

Docket: 30 WAP 2023

Opinion Date: January 22, 2025

Judge: David Wecht

Areas of Law: Criminal Law

On May 8, 2020, Sergeant Aaron Scott and Officer Samuel Greco of the Frazer Township Police Department responded to a rollover vehicle accident. They found Jarren Crosby and a female companion near the overturned vehicle. Crosby admitted to driving, and the officers detected signs of marijuana use. Crosby was unsteady and had slurred speech. When the officers detained him for a DUI investigation, Crosby became agitated and resisted arrest. Officer Greco attempted to handcuff Crosby, who resisted by pulling away and screaming. Greco then tackled Crosby and used a taser to subdue him. Crosby was charged with multiple offenses, including DUI and resisting arrest.

The Court of Common Pleas of Allegheny County convicted Crosby of DUI, resisting arrest, and careless driving, while acquitting him of other charges. Crosby was sentenced to four days in the DUI Alternative to Jail Program and fifteen months’ probation. Crosby’s post-sentence motions were denied, and he appealed, challenging the sufficiency of the evidence for his resisting arrest conviction.

The Superior Court of Pennsylvania affirmed the trial court’s judgment, holding that the evidence was sufficient to support Crosby’s conviction for resisting arrest. The court noted that Crosby’s resistance required substantial force to overcome, as Officer Greco had to tackle him and use a taser.

The Supreme Court of Pennsylvania reviewed the case and affirmed the Superior Court’s decision. The court clarified that the offense of resisting arrest under the second variant of the statute involves the defendant employing means that justify or require substantial force to overcome the resistance. The court held that Officer Greco’s tackle of Crosby constituted substantial force, and thus, the evidence was sufficient to support Crosby’s conviction for resisting arrest. The judgment of the Superior Court was affirmed, and the case was remanded to correct a scrivener’s error in the sentencing order.

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Commonwealth v. Roberts

Court: Supreme Court of Pennsylvania

Docket: 16 WAP 2023

Opinion Date: January 22, 2025

Judge: David Wecht

Areas of Law: Criminal Law

William Roberts was convicted of statutory sexual assault, sexual assault, corruption of the morals of a minor, and indecent assault in 2005. He was sentenced to one and a half to three years in prison and required to register as a sexual offender for life under Megan’s Law III. Roberts complied with his registration obligations until 2019 but failed to report in 2020. The Pennsylvania State Police (PSP) discovered that Roberts no longer lived at his registered address and had not updated his information, leading to his arrest and charges for failing to comply with registration requirements.

The Court of Common Pleas of Fayette County convicted Roberts of two counts of failure to comply with registration requirements and sentenced him to five to ten years in prison. Roberts appealed, arguing that the Commonwealth failed to prove he knew he was required to register. The Superior Court affirmed the conviction, holding that the crime occurred when Roberts knowingly failed to register or verify his residence, regardless of whether he knew he was required to do so.

The Supreme Court of Pennsylvania reviewed the case to determine if the Commonwealth must prove that a sexual offender knew of their registration obligations to convict them of failure to comply. The Court held that the Commonwealth must prove the offender knew of their SORNA obligations. However, the Court found sufficient evidence that Roberts knew of his lifetime registration requirement, as he had signed forms acknowledging this multiple times. Thus, the Supreme Court affirmed the judgment of sentence.

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Martinez v. State of Rhode Island

Court: Rhode Island Supreme Court

Docket: 21-292

Opinion Date: January 23, 2025

Judge: William P. Robinson

Areas of Law: Criminal Law

In 1991, Francisco Martinez was indicted on charges including first-degree murder and assault with a dangerous weapon. In 1993, he was convicted and sentenced to life imprisonment for the murder and a consecutive twenty-year sentence for the assault, with five years to serve and the remainder suspended with probation. Martinez's convictions were affirmed in 1995. In 2021, Martinez filed for postconviction relief, arguing that his sentences should be aggregated for parole eligibility, making him eligible after serving 16 years and 8 months. He claimed that the Rhode Island Department of Corrections (RIDOC) had unlawfully altered its method of calculating parole eligibility, requiring him to be paroled from his life sentence to his consecutive sentence before being eligible for release to the community.

The Superior Court granted Martinez's application for postconviction relief, ruling that his sentences should be aggregated and ordering the Parole Board to release him to the community. The state petitioned for a writ of certiorari, arguing that the hearing justice erred in aggregating the sentences and in ordering Martinez's immediate release.

The Rhode Island Supreme Court reviewed the case. Citing its recent decision in Neves v. State, the Court affirmed the aggregation of Martinez's sentences for parole eligibility purposes. However, the Court quashed the part of the Superior Court's judgment that ordered Martinez's immediate release to the community, holding that the hearing justice exceeded his authority. The Parole Board had only paroled Martinez to his consecutive sentence, not to the community, and the normal parole processes must be followed before any release to the community can be considered. The case was remanded to the Superior Court with instructions to remand it to the Parole Board for further proceedings.

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State v. Geter

Court: South Carolina Supreme Court

Docket: 28256

Opinion Date: January 23, 2025

Judge: John C. Few

Areas of Law: Criminal Law

In the early morning of March 7, 2015, Robert Xavier Geter and James Lewis engaged in a fight at Culler's Bar in Columbia, South Carolina. The altercation moved outside, where Geter stabbed Lewis, who later died from his injuries. During the incident, Geter also stabbed Clarence Stone, causing permanent blindness in one eye. Geter claimed self-defense, stating he was attacked by multiple people and only used his knife to defend himself.

The State indicted Geter for murder and attempted murder, arguing that Geter intended to kill Lewis and that this intent transferred to Stone when he was stabbed. The trial court instructed the jury on the doctrine of transferred intent, and Geter was convicted of both charges. Geter appealed, arguing that transferred intent should not apply to attempted murder and that certain testimony constituted improper bolstering.

The South Carolina Court of Appeals reversed Geter's attempted murder conviction, holding that the State needed to prove Geter specifically intended to kill Stone, which was not the State's theory. The court also found that some testimony constituted improper bolstering but deemed it harmless, affirming the murder conviction. Judge Geathers dissented on the transferred intent issue.

The South Carolina Supreme Court reviewed the case and held that the doctrine of transferred intent does not apply to attempted murder. The court affirmed the Court of Appeals' decision to reverse Geter's attempted murder conviction and upheld the murder conviction, agreeing that the error in admitting the bolstering testimony was harmless.

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The State v. Stoots

Court: South Carolina Supreme Court

Docket: 28253

Opinion Date: January 23, 2025

Judge: John C. Few

Areas of Law: Criminal Law

Jason Edwin Stoots was convicted of second-degree domestic violence following an altercation with his wife, Kimberly, in a Taco Bell drive-thru. Stoots claimed that Kimberly attacked him first, and he accidentally struck her while trying to defend himself. Kimberly testified that Stoots punched her without provocation. The trial court refused to instruct the jury on self-defense and accident, leading to Stoots's conviction.

The Circuit Court Judge denied Stoots's request for jury instructions on self-defense and accident, reasoning that Stoots could have left the altercation and that the size difference between him and Kimberly made self-defense inapplicable. The jury was instructed that the State must prove Stoots acted with criminal intent. The jury found Stoots guilty of second-degree domestic violence. Stoots appealed, and the Court of Appeals affirmed the conviction.

The Supreme Court of South Carolina reviewed the case and found that the trial court erred in refusing to charge the jury on self-defense. The court held that if there is any evidence from which the jury could reasonably conclude the defendant acted in self-defense, it is reversible error not to instruct the jury on that point. The court disagreed with the State's argument that self-defense was inapplicable due to Stoots's claim of unintentional action. The court also found that the proportionality of Stoots's response to Kimberly's attack was a question for the jury. However, the court found no reversible error in the trial court's refusal to charge the law of accident, as the jury was adequately instructed on the requirement of criminal intent. The Supreme Court reversed the Court of Appeals' decision and remanded the case for a new trial.

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STATE v. CUARENTA

Court: Texas Court of Criminal Appeals

Docket: PD-0205-24

Opinion Date: January 22, 2025

Judge: Jesse McClure

Areas of Law: Criminal Law

The appellee was stopped and ticketed for driving 82 mph in a 60-mph zone, a Class C misdemeanor. In the Justice Court for Precinct 1 of Brazos County, he pleaded no contest and was found guilty, with the court assessing his fine and fees. He then filed a de novo appeal in the County Court at Law Number 2, pleaded not guilty, and was found guilty again. The county court suspended his sentence, deferred the disposition, and placed him on probation for 180 days.

The State appealed to the Tenth Court of Appeals, arguing that the deferred disposition was illegal because the appellee held a commercial driver’s license, disqualifying him from community supervision. The Texas Supreme Court transferred the case to the Seventh Court of Appeals. The Seventh Court questioned its jurisdiction but followed the Tenth Court's precedent, exercised jurisdiction, and reversed the trial court’s decision, remanding for proper sentencing. The appellee then filed a petition for discretionary review.

The Court of Criminal Appeals of Texas reviewed the case and held that an order of deferred disposition is not a "sentence" under Article 44.01(b) of the Texas Code of Criminal Procedure. The court concluded that the Court of Appeals lacked jurisdiction over the appeal because a deferred disposition does not meet the statutory definition of a sentence, which requires an order that the punishment be carried into execution. Consequently, the Court of Criminal Appeals reversed the decision of the Court of Appeals.

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STATE v. HATTER

Court: Texas Court of Criminal Appeals

Docket: PD-0160-24

Opinion Date: January 22, 2025

Judge: David Newell

Areas of Law: Criminal Law

The State of Texas charged the appellee with felony assault of a peace officer. During plea negotiations, the State offered to dismiss the felony charge if the appellee agreed to plead guilty to two DWI charges. However, the appellee never agreed to this plea deal. Despite this, the State dismissed the felony and DWI charges but later refiled the felony under a new cause number. The appellee filed a motion for specific performance, seeking to enforce the dismissal of the refiled felony, alleging that the prosecutor had promised not to refile the charge.

The trial court granted the appellee’s motion for specific performance, directing the State to dismiss the refiled felony assault charge. The State appealed, arguing that no enforceable plea agreement existed. The Fourteenth Court of Appeals affirmed the trial court’s decision, concluding that there was an immunity from prosecution agreement between the State and the appellee, which the trial court approved. Justice Jewell dissented, arguing that no such agreement existed and that there was no consideration for the prosecutor’s promise.

The Court of Criminal Appeals of Texas reviewed the case and concluded that there was no enforceable plea agreement. The court held that the prosecutor’s promise to dismiss the felony assault case and not refile it did not constitute an immunity agreement or a binding plea bargain agreement. The court noted that the appellee never agreed to the terms of the plea offer, and the trial court never approved any such agreement. Therefore, the court reversed the judgment of the court of appeals and entered a judgment reversing the trial court’s order granting the appellee’s motion for specific performance.

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State v. Morgan

Court: Washington Supreme Court

Docket: 102,643-9

Opinion Date: January 23, 2025

Judge: Debra Stephens

Areas of Law: Criminal Law, Public Benefits

Montreal Morgan participated in a home invasion robbery that resulted in the death of Fabian Alvarez. Following the incident, the Department of Labor and Industries (L&I) paid $10,480 in benefits under Washington’s Crime Victims Compensation Act (CVCA) for Alvarez’s medical and funeral expenses. Morgan pleaded guilty to conspiracy to commit murder in the second degree and unlawful possession of a firearm in the second degree. At his restitution hearing, Morgan requested a reduction in the restitution amount due to mitigating factors, but the trial court believed it lacked discretion under RCW 9.94A.753(7) and ordered the full amount of restitution requested by the State.

The trial court’s decision was affirmed by the Court of Appeals, which agreed that RCW 9.94A.753(7) does not afford trial courts discretion to impose less restitution than the amount of CVCA benefits paid. Morgan then petitioned for review, which was granted by the Supreme Court of the State of Washington.

The Supreme Court of the State of Washington held that RCW 9.94A.753(7) does not allow a trial court discretion to modify the amount of restitution owed to L&I for CVCA benefits. The court emphasized that the statutory language is unambiguous and requires the court to order restitution in the amount of benefits paid by L&I. The court affirmed the Court of Appeals' decision and upheld Morgan’s restitution order, concluding that the trial court correctly interpreted the statute as mandating full restitution for CVCA benefits without discretion for reduction based on mitigating factors.

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