Criminal Law - Justia Case Law Summaries

Duckett v. State

2026-07-08T12:04:29-08:00

James Aren Duckett, a police officer, was convicted nearly forty years ago of the sexual battery and first-degree murder of eleven-year-old Teresa McAbee. On the night of May 11, 1987, Duckett was the only officer on patrol in Mascotte, Florida and was the last person seen with Teresa in his patrol car. Circumstantial evidence, including tire tracks and comingled fingerprints from the victim and Duckett on his patrol car, implicated him. Teresa’s body was found the next morning, and a medical examiner determined she had been sexually assaulted, strangled, and drowned. The jury found Duckett guilty and recommended a death sentence, which the trial court imposed after finding aggravating circumstances. Duckett’s conviction and sentence were affirmed by the Supreme Court of Florida in 1990. He subsequently sought postconviction relief several times in both state and federal courts, but all motions and petitions were denied. After a death warrant was signed in 2026, Duckett filed for postconviction DNA testing, which the circuit court granted. He then filed his fifth successive postconviction motion under Rule 3.851, raising claims of actual innocence and alleged constitutional violations. Before DNA testing results were available, the circuit court summarily denied his motion and declined to stay his execution. Duckett appealed and requested a stay, which the Supreme Court of Florida granted to allow completion of DNA testing. The Supreme Court of Florida reviewed the circuit court’s summary denial de novo. Duckett’s DNA testing results were found inconclusive, and his claims of actual innocence and constitutional violations lacked merit under Florida law. The Court affirmed the circuit court’s denial of Duckett’s fifth successive postconviction motion, denied his habeas petition, and lifted the stay of execution. No rehearing would be considered, and the mandate issued immediately. View "Duckett v. State" on Justia Law

Sochor v. State

2026-07-08T12:04:29-08:00

In 1981, Dennis Sochor murdered Patricia Gifford after she refused his sexual advances; her body was never recovered. Sochor, who had fled the state after seeing himself on television, was apprehended in Georgia five years later and confessed multiple times to the crime. At trial, the jury found him guilty of kidnapping and first-degree murder, recommending a death sentence by a 10-2 vote. The trial court imposed the death penalty, finding four aggravating factors and no mitigating circumstances. On direct appeal, the Supreme Court of Florida affirmed Sochor’s conviction and sentence but was later instructed by the United States Supreme Court to conduct a harmless error analysis regarding one aggravator. After doing so, the Florida court again affirmed. Sochor's conviction and sentence became final in 1993. Since then, he has pursued numerous postconviction challenges in both state and federal courts, all unsuccessful. After the Governor signed a death warrant in June 2026, Sochor filed a sixth successive postconviction motion in the Circuit Court for Broward County, raising two claims: a Brady/Giglio violation concerning a 2022 letter to his brother, and a facial challenge to Florida’s lethal injection protocol. The circuit court summarily denied both claims as untimely, procedurally barred, and without merit. The Supreme Court of Florida reviewed the summary denial de novo and affirmed the circuit court’s ruling. The court held that Sochor’s method-of-execution claim was untimely because the evidence on which it relied had been discoverable since at least 2017, and that the claim was meritless because similar challenges to Florida’s lethal injection protocol had repeatedly been rejected. The court also denied Sochor’s motion for a stay of execution and declined to hold oral argument or entertain a motion for rehearing. View "Sochor v. State" on Justia Law

People v. Brim

2026-07-08T12:03:25-08:00

The case centers on an altercation that occurred on a BART train in Alameda County in November 2019. Jermaine Brim, the defendant, boarded the train, interacted with Oliver Williams, and a physical fight ensued. Williams, at one point, drew a knife and attempted to stab Brim. Brim ultimately gained control of the knife, fatally stabbed Williams, and fled the scene. The incident was recorded on surveillance cameras, and Brim was later apprehended after additional encounters with others outside the train. The Alameda County Superior Court charged Brim with murder and tried him before a jury. Brim testified, claiming he acted in self-defense. The jury deliberated over several days, asked multiple questions regarding the distinctions between murder and voluntary manslaughter, and specifically about the application of self-defense instructions. The trial court responded to these questions by directing the jury to reread specific instructions but did not clarify the distinction between perfect and imperfect self-defense in relation to the cessation of danger. Ultimately, the jury found Brim guilty of second-degree murder, and he was sentenced to 16 years to life in prison. The California Court of Appeal, First Appellate District, Division Two, reviewed the case. The appellate court held that the trial court abused its discretion by failing to adequately respond to the jury’s question regarding whether imperfect self-defense could apply after the objective danger had ceased, as outlined in CALCRIM No. 3474. The appellate court found this error prejudicial, as there was a reasonable probability that the outcome might have differed if the jury’s confusion had been resolved. As a result, the court reversed Brim’s conviction for second-degree murder and held that, unless the prosecution elects to retry him for murder, the judgment should be modified to reflect a conviction for voluntary manslaughter. View "People v. Brim" on Justia Law

People v. Sacco

2026-07-08T12:03:24-08:00

The defendant was charged with several financial crimes, including identity theft, forgery, and grand theft, after opening bank accounts under false pretenses and misappropriating funds that belonged to a local American Legion post. Investigations revealed that he had intercepted a donation check intended for the organization, requested a replacement, and deposited it into an account under his control, among other acts involving fraudulent documents and unauthorized transfers of large sums. The defendant was not a member of the organization but had access to its mail and financial information through his business, which operated in the same building. The Superior Court of Los Angeles County reviewed the defendant’s motion for pretrial mental health diversion under Penal Code section 1001.36. He presented a psychologist’s report diagnosing him with persistent depressive disorder with anxious distress, arguing that his mental condition was a significant factor in the commission of the offenses. The People opposed the motion, contending that his mental disorder did not contribute to his crimes, citing the sophistication and planning involved. The trial court found that, although the defendant had a qualifying mental disorder and was not a public safety risk, the evidence rebutted the statutory presumption that the mental disorder was a significant factor in the offenses, primarily because the expert report did not explain how his symptoms contributed to the criminal conduct and the court found the crimes inconsistent with those symptoms. The trial court denied the motion, and the defendant subsequently pled no contest to grand theft. On appeal, the California Court of Appeal, Second Appellate District, Division Four, considered whether the trial court properly denied the motion for mental health diversion. The appellate court held that the trial court did not abuse its discretion, properly applied the statutory presumption, and its finding that the presumption was rebutted by clear and convincing evidence was supported by substantial evidence. The judgment was affirmed. View "People v. Sacco" on Justia Law

US v. Carson

2026-07-08T10:30:41-08:00

Officers responding to reports of suspected drug activity at a public housing development in Asheville, North Carolina, began surveilling individuals frequenting the area. One individual, Jermaine Derrick Carson, Jr., was observed as a passenger in a vehicle whose driver had a suspended license. Weeks later, during a joint law enforcement operation targeting crime near downtown bars, officers recognized the same vehicle at a gas station and initiated a traffic stop before it returned to the housing complex. During the stop, officers detected the odor of marijuana and observed drug paraphernalia in the car. Carson was frisked and found to possess a loaded firearm. After Carson was indicted for possession of a firearm by a convicted felon in the United States District Court for the Western District of North Carolina, he moved to suppress the firearm, arguing that the traffic stop was unlawfully prolonged and that the frisk lacked reasonable suspicion. A magistrate judge held an evidentiary hearing, during which officers testified and body camera footage was reviewed. The magistrate judge recommended denial of the suppression motion, finding the officers had probable cause to search the vehicle after the detection of marijuana and that the frisk was lawful. The district court adopted the recommendation, denied the motion, and subsequently accepted Carson’s conditional guilty plea, sentencing him to 24 months imprisonment. The United States Court of Appeals for the Fourth Circuit reviewed the district court’s decision, applying de novo review for legal questions and clear error for factual findings. The court held that the officers had independent reasonable suspicion—specifically, the detection of marijuana odor—which justified the extension of the stop and the search. Additionally, the frisk was permissible due to reasonable suspicion of illegal drugs in the vehicle. The Fourth Circuit affirmed the district court’s denial of Carson’s suppression motion. View "US v. Carson" on Justia Law

Steen v. Dismukes

2026-07-08T10:30:39-08:00

George Steen, a foster parent, was convicted by a North Carolina jury of sexually abusing a young foster child, M.S., who had lived with Steen and his wife for several years. The prosecution relied heavily on M.S.’s detailed descriptions of the alleged abuse, arguing such knowledge was unlikely unless M.S. had experienced the acts. The defense countered by attempting to show M.S.’s reputation for untruthfulness and identifying alternative sources for his sexual knowledge, including prior experiences with his biological family and other incidents. Despite this, the jury found Steen guilty on three counts of sexual offenses against a child. Following his conviction, Steen sought relief in the North Carolina state courts, arguing ineffective assistance of counsel under the Sixth Amendment, as articulated in Strickland v. Washington. He focused on his attorney’s failure to uncover and present specific social services records, counselor’s notes, and medical records that, he claimed, further supported his theory that M.S. fabricated the allegations and had other sources of sexual knowledge. The state trial court denied relief, finding Steen failed to demonstrate both deficient performance and resulting prejudice. The North Carolina Court of Appeals affirmed, assuming deficient performance but holding Steen could not show prejudice because the additional records were cumulative of evidence already before the jury. Steen then filed for federal habeas relief in the United States District Court for the Western District of North Carolina. That court denied relief but erroneously deferred to the trial court’s analysis of deficient performance rather than the appellate court’s reasoning on prejudice. On appeal, the United States Court of Appeals for the Fourth Circuit clarified that only the last reasoned decision of the North Carolina Court of Appeals was entitled to deference under 28 U.S.C. § 2254(d). The Fourth Circuit held that this court had reasonably found no prejudice, and thus affirmed the denial of habeas relief. View "Steen v. Dismukes" on Justia Law

US v. Williams

2026-07-08T10:30:38-08:00

Police officers responded to an anonymous 911 call reporting that individuals inside a white Mercedes sedan parked near the pool area of an apartment complex might be selling or possessing narcotics. The officers received this information through their department’s computer-aided dispatch system. Upon arrival, the officers stopped their marked police vehicles in the roadway, positioning themselves such that one car was partially in front of the Mercedes and another behind. They exited their vehicles, approached the Mercedes, and immediately smelled marijuana. Williams, the defendant, admitted to smoking marijuana, after which he and the other occupants were directed to exit the vehicle. In the ensuing search, officers found a handgun, and Williams admitted ownership. The United States District Court for the Western District of North Carolina denied Williams’ motion to suppress the evidence found during the search. The district court found that Williams was not seized when the officers stopped their cars, reasoning that there was physical room for him to leave and a reasonable person would have felt free to do so. The court further concluded that the officers had reasonable suspicion to seize Williams after smelling marijuana and that the search was supported by probable cause. Williams was subsequently convicted of being a felon in possession of a firearm after a bench trial. On appeal, the United States Court of Appeals for the Fourth Circuit held that Williams was seized for Fourth Amendment purposes when the officers blocked his vehicle with their marked patrol cars, as a reasonable person would not have felt free to leave under the circumstances. The court further held that the officers lacked reasonable suspicion to justify this seizure based solely on the anonymous tip and the fact the encounter occurred in a high-crime area. The court reversed the district court’s denial of the suppression motion, vacated Williams’ conviction, and remanded for further proceedings. View "US v. Williams" on Justia Law

State v. Schuster

2026-07-08T08:40:37-08:00

The defendant in this case was arrested following a traffic stop and charged with several offenses, including receiving or transferring a stolen motor vehicle and possession of a controlled substance. He was released on his own recognizance the same day and remained at liberty under court-imposed conditions. More than three years elapsed between his arrest and the district court’s decision on his motion to dismiss for violation of his right to a speedy trial. During this period, delays were attributed to procedural extensions, COVID-19-related jury trial suspensions, and significant systemic backlog in the local court system, which the district court found was exacerbated by prosecutorial policy. The district court, applying the four-factor test from Barker v. Wingo and New Mexico precedent, found that the length of delay was presumptively prejudicial, most of the delay was attributable to the State, and the defendant had adequately asserted his right to a speedy trial. The court also found that the defendant suffered particularized prejudice and alternatively presumed prejudice due to governmental indifference. As a result, the district court dismissed the charges with prejudice. The State appealed. The New Mexico Court of Appeals reversed, finding that the defendant did not show particularized prejudice and that the other Barker factors did not all weigh heavily enough against the State to excuse the absence of such a showing. The Court of Appeals weighed the State’s culpability as only “moderately to heavily” against it and reduced the impact of the defendant’s assertions of his right, viewing them as largely pro forma. The Supreme Court of the State of New Mexico reversed the Court of Appeals, holding that the first three Barker factors—length of delay, reasons for delay, and assertion of the right—each weighed heavily against the State. The Court concluded that, under New Mexico law, when these three factors weigh heavily against the State, a showing of particularized prejudice is not required, and the defendant’s right to a speedy trial was violated. The Court remanded for dismissal with prejudice. View "State v. Schuster" on Justia Law

State v. Causey

2026-07-08T08:40:36-08:00

Two days after a double homicide occurred in Bernalillo County, New Mexico, a vehicle registered in New Mexico was stopped in Wheeler County, Texas, for an equipment violation. The defendant was a passenger in the vehicle. During the stop, the Texas deputy sheriff questioned the driver, who eventually admitted there was marijuana in the car. The deputy conducted a probable cause search, detained the defendant, and discovered a handgun, later linked to the New Mexico homicides. The defendant was indicted in New Mexico on charges related to the homicides and other crimes. He moved to suppress the physical evidence and statements obtained during the Texas stop, arguing the search violated both the U.S. Constitution and Article II, Section 10 of the New Mexico Constitution. The State argued Texas law should govern the admissibility of the evidence, as the search occurred in Texas and was lawful there. The District Court of Bernalillo County disagreed, applying New Mexico’s exclusionary rule and suppressing the evidence, relying on New Mexico cases concerning evidence gathered by federal agents within New Mexico. The Supreme Court of the State of New Mexico reviewed whether the district court correctly applied New Mexico’s constitutional exclusionary rule to evidence obtained in another state, where the search complied with that state’s law but would violate New Mexico’s constitution. The court held that Article II, Section 10 of the New Mexico Constitution governs the admissibility of evidence in New Mexico courts, regardless of whether the evidence was obtained by out-of-state law enforcement in compliance with their own laws. Evidence gathered in violation of Article II, Section 10 is inadmissible in New Mexico courts. The court affirmed the district court’s order suppressing the evidence. View "State v. Causey" on Justia Law

USA v. Theiler

2026-07-07T15:30:30-08:00

A laboratory testing company, Boston Heart Diagnostics (BHD), and two rural Texas hospitals, Little River Health Care and Integrity Transitional Hospital, entered into arrangements where affiliated physicians referred blood tests to the hospitals, which then billed payors, including Medicare, at advantageous rates. The hospitals used Management Service Organizations (MSOs) as intermediaries to recruit and pay physicians, and BHD’s sales team—including several defendants—facilitated these relationships. Evidence at trial showed MSOs were used to provide kickbacks to physicians based on referral volume, disguised through sham contracts, resulting in unusually high revenues for BHD. The defendants included BHD’s CEO, vice president of sales, and sales representatives, who were involved in managing and growing these partnerships. A federal grand jury indicted eighteen individuals for conspiracy to commit illegal remunerations in violation of the Anti-Kickback Statute (AKS) and 18 U.S.C. § 371. Five defendants proceeded to a joint jury trial in the United States District Court for the Eastern District of Texas. The government presented testimony from co-conspirators and documentary evidence to show the existence of the scheme and the defendants’ knowledge and participation. The jury found all five guilty of conspiracy. The court denied post-trial motions for acquittal or a new trial, sentenced the defendants, and four of them appealed. The United States Court of Appeals for the Fifth Circuit reviewed the sufficiency of the evidence de novo and other claims under deferential standards. The court affirmed all convictions, holding that a rational jury could find beyond a reasonable doubt that the defendants knowingly and willfully joined a conspiracy to pay illegal kickbacks to induce referrals for federally insured patients. The court also held there was sufficient evidence of a federal nexus and no error in the district court’s handling of jury notes or instructional refusals. The convictions and sentences were affirmed. View "USA v. Theiler" on Justia Law

USA v. Quintanilla

2026-07-07T15:30:30-08:00

A defendant pleaded guilty to transporting child pornography pursuant to a written plea agreement with the government. In exchange for the dismissal of two more serious charges—sexual exploitation of a minor and possession of child pornography—the defendant admitted guilt to the transportation offense. The plea agreement included an appellate waiver, allowing appeals only for claims of ineffective assistance of counsel. The defendant confirmed in court that he understood the agreement’s terms, including the maximum penalties and mandatory restitution. At sentencing, the court imposed 240 months’ imprisonment, lifetime supervised release, and $17,500 in restitution to two victims. The United States District Court for the Southern District of Texas accepted the defendant's guilty plea and sentenced him according to the statutory maximum and mandatory minimums outlined in the plea agreement. The court also conducted a joint change-of-plea hearing for the defendant and another individual, advising both about appellate rights. The presentence report attributed 3,092 images of child pornography to the defendant, and the court considered victim-impact statements and restitution requests before issuing its sentence. The defendant did not object to the restitution calculation at sentencing. On appeal to the United States Court of Appeals for the Fifth Circuit, the defendant argued that the district court misled him regarding his appellate rights during the plea colloquy, imposed unreasonable prison and supervised release terms, and failed to properly analyze causation and apportionment for restitution as required by Paroline v. United States. The Fifth Circuit held that the appellate waiver was knowing and voluntary, barring challenges to the conviction, sentence, and restitution. The court found no plain error in the district court’s advisement or restitution calculation and affirmed the judgment. View "USA v. Quintanilla" on Justia Law

State v. Twardoski

2026-07-07T14:10:59-08:00

The defendant was convicted of multiple felony charges related to sexual abuse, including three counts of sexual intercourse without consent and one count of sexual assault, based on allegations by a minor, I.A., that he had abused her using a game called "Truth or Dare." His defense asserted that I.A. fabricated the allegations by accusing him of the same conduct that another man, Cody Hill, had perpetrated against her two weeks earlier. The defendant argued that I.A. disliked him for providing drugs to her mother and sought to protect her mother by removing him from her life. Expert testimony was presented during the trial regarding victim selection and the increased likelihood of revictimization for children previously abused. After the initial conviction in the District Court of the Twenty-First Judicial District, Ravalli County, the defendant appealed to the Supreme Court of Montana. The Supreme Court previously reversed the conviction in State v. Twardoski, 2021 MT 179, finding that the defendant was wrongly barred from presenting evidence about I.A.’s prior abuse by another person, violating his right to confront his accuser and present a complete defense. The case was remanded for a new trial before a different judge. At retrial, the sexual abuse of children charge was dropped, but the defendant was again convicted of the remaining charges. He received concurrent 50-year sentences with no time suspended and a 25-year parole restriction. On appeal to the Supreme Court of the State of Montana, the defendant raised two issues: ineffective assistance of counsel for failing to object to statistical expert testimony, and whether the more severe sentence imposed after retrial violated his right to due process. The Supreme Court declined to review the ineffective assistance claim on direct appeal, finding plausible tactical reasons for counsel’s lack of objection. The Court held that the increased sentence was not the result of judicial vindictiveness, as there were legitimate, nonvindictive reasons for the parole restriction. The conviction and sentence were affirmed. View "State v. Twardoski" on Justia Law

State v. Morris

2026-07-07T14:10:53-08:00

The defendant was convicted of Sexual Intercourse Without Consent and Solicitation of Tampering with Physical Evidence after living with the victim, her husband, and their children. The offense occurred when the victim, BB, alleged that the defendant raped her while they were alone in the apartment. BB initially confided in her ex-husband and later her husband before reporting the incident to the police, leading to a recorded interview in which the defendant admitted to intercourse but claimed it was consensual. The case involved text messages referencing BB’s past experiences and issues of credibility. Prior to trial, the State moved to exclude evidence of the victim’s prior sexual history under Montana’s rape shield law. The defendant sought to introduce text messages and statements suggesting BB had previously made false rape accusations and been unfaithful during a prior marriage, arguing these were relevant to her credibility and motive. The Eighth Judicial District Court granted the State’s motion in limine, finding the defendant’s offers speculative and unsupported, and excluded this evidence. During trial, the court allowed the introduction of some text messages but maintained the exclusion of evidence regarding prior false allegations and infidelity due to the lack of a proper offer of proof. The court also imposed a discovery sanction when the defendant attempted to introduce undisclosed investigator notes about the victim’s alleged infidelity. The defendant was found guilty and sentenced, with several probation conditions restricting contact with minors. The Supreme Court of the State of Montana affirmed the exclusion of evidence about the victim’s past sexual history and prior rape allegations, holding there was no abuse of discretion because the defendant failed to provide the required evidentiary foundation. The court also upheld the discovery sanction for failure to disclose evidence. However, it reversed and remanded probation conditions restricting contact with minors, finding no nexus between the crime and those restrictions, and required further findings if such conditions are reimposed. The judgment was affirmed in part, reversed in part, and remanded. View "State v. Morris" on Justia Law

US v. Johnson

2026-07-07T13:30:02-08:00

The defendant was investigated after law enforcement used a specialized tool called Freenet Roundup, which is a modified version of a peer-to-peer software called Freenet. Freenet allows users to share files anonymously, but its Opennet mode warns users that their identity could be discovered and their IP address is visible to strangers. Freenet Roundup, available only to law enforcement, logs requests for known child sexual abuse material (CSAM) and uses a formula to help identify whether a request came from an original source or was simply relayed. After Freenet Roundup flagged requests associated with the defendant’s IP address for CSAM, the FBI obtained a search warrant for his residence, finding devices containing child pornography. The defendant was charged in the United States District Court for the District of Massachusetts with possession of child pornography. Before trial, he moved to suppress the evidence, arguing that law enforcement’s use of Freenet Roundup constituted an unlawful Fourth Amendment search, as he claimed a reasonable expectation of privacy in his Freenet transmissions. The district court denied the motion, reasoning that because the defendant voluntarily used Freenet’s Opennet mode, which warns of identity risks and connections with strangers, he lacked a reasonable expectation of privacy in the relevant activity. The court distinguished this case from Carpenter v. United States, finding that law enforcement’s actions did not amount to wholesale surveillance or use of technology not in general public use. The defendant then entered a conditional guilty plea, preserving his right to appeal the suppression ruling. On appeal, the United States Court of Appeals for the First Circuit reviewed the district court’s findings for clear error and its legal conclusions de novo. The First Circuit held that a defendant lacks a reasonable expectation of privacy in activity voluntarily shared on publicly-available peer-to-peer networks like Freenet’s Opennet mode. The court affirmed the district court’s denial of the suppression motion. View "US v. Johnson" on Justia Law

Young vs. State

2026-07-07T12:30:04-08:00

After a bench trial, the appellant was convicted of first-degree murder and armed criminal action for the death of her husband. She was sentenced to life without parole and 30 years to be served concurrently. While her direct appeal was still pending, she filed a pro se motion under Missouri Supreme Court Rule 29.15 to set aside her conviction. The circuit court later appointed counsel for her postconviction proceeding. After the Missouri Court of Appeals affirmed her conviction and issued its mandate, appointed counsel entered an appearance but did not file an amended motion until after the deadline established by Rule 29.15. The Circuit Court of Douglas County found both the pro se and amended motions were untimely but determined appointed counsel had abandoned the appellant by failing to timely file the amended motion. The court proceeded to deny relief on the merits of the ineffective assistance of counsel claims asserted in the amended motion, including failure to call an expert on psychological shock and failure to request a competency evaluation, without holding an evidentiary hearing. The Supreme Court of Missouri reviewed the appeal. It held that the pro se motion was timely under the applicable version of Rule 29.15, as it was deemed filed immediately after the appellate mandate. However, the amended motion was untimely. The Court concluded the motion court properly found abandonment by appointed counsel, as the tardiness was solely counsel’s fault and supported by the record. In such cases, the amended motion should be treated as timely and the court may review its merits without remand for an abandonment hearing. On the merits, the Supreme Court of Missouri held the motion court did not clearly err in denying both ineffective assistance claims without an evidentiary hearing because the record refuted any showing of prejudice or need for further factual development. The judgment denying postconviction relief was affirmed. View "Young vs. State" on Justia Law

USA v. Martinez

2026-07-07T08:30:47-08:00

A semi-truck driver was stopped in Illinois after state police received a tip from another law enforcement agency that the truck was carrying a large amount of narcotics. Two K9 troopers, not on routine patrol, waited on the side of the highway in the early morning hours to intercept the vehicle. The stated purpose for the stop was to conduct an administrative Level 3 inspection under Illinois’s commercial trucking regulatory scheme, involving checks of driver and vehicle documents. During the stop, the trooper noticed several signs he considered suspicious, including an odor of air freshener and irregularities with the driver’s route and cargo. A dog sniff of the truck led to the discovery of narcotics, and the driver was arrested. The United States District Court for the Central District of Illinois heard the defendant’s suppression motion, in which he argued the stop was a pretextual administrative inspection aimed solely at investigating criminal activity, thus violating the Fourth Amendment. The district court denied the motion, reasoning that the officer’s subjective intent was irrelevant so long as the stop was authorized under Illinois’s regulatory scheme. On appeal, the United States Court of Appeals for the Seventh Circuit held that, in the context of administrative inspections, an officer’s actual motivation for conducting the stop is relevant. The court found that the evidence showed the stop was undertaken solely to further a criminal investigation, not to enforce administrative regulations. It further held that the government had failed to demonstrate the stop was justified in its inception under the administrative inspection exception to the warrant requirement. The court concluded that the evidence obtained as a result of the stop must be suppressed and that the good faith exception to the exclusionary rule did not apply. The Seventh Circuit reversed the district court’s denial of the suppression motion and remanded for further proceedings. View "USA v. Martinez" on Justia Law

USA v. De Moya

2026-07-07T07:32:02-08:00

Two business owners in Washington, D.C. sought to reduce their businesses’ tax liabilities by hiring an intermediary who, in turn, paid cash bribes to a supervisor in the D.C. Office of Tax and Revenue. The supervisor used his access to the agency’s tax system to reduce the businesses’ tax obligations without legitimate justification, sometimes using colleagues’ credentials and creating false documents to conceal the scheme. The intermediary relayed proof of these illicit adjustments to his clients, who paid him and the supervisor a share of the savings. The scheme resulted in a loss of approximately $2.3 million to the District of Columbia. After an audit uncovered suspicious tax reductions without proper documentation, authorities traced the scheme to the supervisor, the intermediary, and the clients. Two of the intermediary’s clients pleaded guilty and cooperated with the government. The United States District Court for the District of Columbia tried the case against the intermediary and one client. The jury convicted both defendants of conspiracy, bribery, and wire fraud, while acquitting one defendant on some wire fraud counts. The district court imposed sentences of 110 months and 30 months, respectively. On appeal to the United States Court of Appeals for the District of Columbia Circuit, the defendants challenged the sufficiency of the evidence, the bribery jury instructions, one defendant’s claim of ineffective assistance of counsel regarding sentencing, and an alleged sentencing penalty for going to trial. The appellate court held that the evidence was sufficient to support the convictions, the error in the bribery jury instruction was harmless because the evidence demonstrated a quid pro quo for specific official acts, there was no prejudice from counsel’s failure to challenge sentencing policy, and there was no unconstitutional penalty for exercising the right to trial. The court affirmed the district court’s judgments. View "USA v. De Moya" on Justia Law

Allen v. The State of Wyoming

2026-07-07T07:17:35-08:00

The case concerns a defendant who was charged with six counts of first-degree sexual abuse of a minor. After being arrested, he was represented by a court-appointed public defender. He was able to post a $100,000 surety bond, which triggered the public defender to question his eligibility for appointed counsel. At a hearing, the defendant explained that he had lost his job and that the bond was posted using his wife’s credit card and by selling a horse and trailer. His only remaining assets were equity in his home, his wife’s income, and several vehicles, including a car registered in his name but intended for his daughter. The District Court of Laramie County required the defendant to sell the vehicle registered in his name and deposit the proceeds with the court as a condition to keep his public defender. The court’s oral ruling specifically required the sale, while its written order required only the appraised value to be deposited. The defendant complied, depositing approximately $9,600. He later entered into a plea agreement, pleading guilty to three counts, and the court dismissed the rest. He was sentenced to three consecutive terms of 25–35 years, and his deposit was applied to his public defender fees, with the remainder refunded. On appeal, the Supreme Court of Wyoming reviewed whether the defendant had waived his right to challenge the court’s order by pleading guilty and whether the district court had the authority to force the sale of his property as a condition of representation. The court held that the defendant had not waived this issue, as it did not relate to his guilt or conviction. The court further held that the district court exceeded its authority by requiring the forced sale of the vehicle to secure payment for public defender fees. The Supreme Court of Wyoming reversed and remanded for further proceedings. View "Allen v. The State of Wyoming" on Justia Law

United States v. Zephier

2026-07-07T07:01:24-08:00

The case centers on Ellery Zephier, Sr., who was charged with two counts of assault with a dangerous weapon, assault resulting in serious bodily injury, and kidnapping, all arising from conduct toward his ex-girlfriend, Kristy Selwyn, over several days in July 2024. The evidence included testimony from the victim, medical personnel verifying her injuries, and law enforcement officers who corroborated aspects of her account, including finding blood and bloodstained clothing at the scene. The government also presented evidence under Federal Rule of Evidence 404(b) regarding a 2023 incident in which Zephier allegedly assaulted and kidnapped another former girlfriend, Angelique Drapeau. The United States District Court for the District of South Dakota, presided over by Chief Judge Roberto A. Lange, conducted the trial. The district court excluded evidence relating to a 2022 incident with another woman, A.K., but ultimately admitted evidence of the 2023 incident with Drapeau, offering a limiting instruction to the jury. The court also restricted the defense’s cross-examination of Drapeau to prevent introduction of prejudicial and speculative testimony regarding A.K.’s death. The jury acquitted Zephier of assault with a dangerous weapon but convicted him of kidnapping and assault resulting in serious bodily injury. On appeal, Zephier challenged the district court’s admission of the 404(b) evidence, the limits placed on his cross-examination of Drapeau, and the sufficiency of the evidence for both convictions. The United States Court of Appeals for the Eighth Circuit affirmed the district court’s judgment. The appellate court held that the Rule 404(b) evidence was properly admitted, the limitation on cross-examination did not violate the Sixth Amendment, and that sufficient evidence supported both the kidnapping and assault convictions. Thus, the convictions and sentences were upheld. View "United States v. Zephier" on Justia Law

United States v. Salvador

2026-07-07T07:00:03-08:00

A noncitizen defendant, a member of the MS-13 gang, pleaded guilty to assault in aid of racketeering after providing advice and supplies to junior gang members involved in a shooting. He was charged as part of a multi-defendant racketeering indictment covering violent crimes from 2016 to 2018. The defendant was sentenced to 210 months of imprisonment and three years of supervised release. One special condition of his supervised release required him to “cooperate with and abide by all instructions of immigration authorities.” The defendant did not object to this special condition during sentencing. The United States District Court for the Eastern District of New York imposed the sentence and adopted the presentence report’s recommendations, including the special conditions of supervised release. The defendant filed an appeal challenging only the “Immigration Authorities Condition,” arguing that it was procedurally unreasonable, unconstitutionally vague, and impermissibly delegated judicial authority to non-judicial officers. The government argued the appeal was barred by a waiver in the plea agreement, but the United States Court of Appeals for the Second Circuit determined that the waiver did not cover conditions of supervised release and denied the motion to dismiss. The United States Court of Appeals for the Second Circuit reviewed the case for plain error. The court held that the challenge was ripe, was not waived but forfeited, and that the district court’s reasons for imposing the condition were self-evident in the record. The court further held that the condition was not unconstitutionally vague and did not unlawfully delegate sentencing authority. The judgment of the district court, including the challenged special condition, was affirmed. View "United States v. Salvador" on Justia Law

People Of Michigan v. Klungle

2026-07-07T05:00:03-08:00

The case arose from a dispute over property ownership following the death of a homeowner who did not leave a will. The defendant, who had lived in the home with his children and grandmother, refused to leave after her death despite an eviction order. When sheriff’s deputies arrived to enforce the eviction, the defendant resisted leaving and was arrested. As a result, he was charged with trespassing and two counts of resisting or obstructing a police officer. The defendant maintained throughout that he believed he had a right to remain in the home and thus was not trespassing. After a jury trial in Emmet Circuit Court, the defendant was convicted on all counts. He moved for a new trial, arguing that his Sixth Amendment rights were violated when his counsel conceded guilt on the trespassing charge during closing argument without consulting him or securing his consent. At the evidentiary hearing, trial counsel testified that the defendant had consistently maintained his innocence before trial and was not informed of the plan to concede guilt. The trial court denied the motion, reasoning that the defendant failed to cooperate with counsel and did not object to the concession. The Court of Appeals affirmed, finding that counsel acted within his discretion given the lack of communication. The Michigan Supreme Court reviewed the case and held that under McCoy v. Louisiana, a criminal defendant has the right to decide the objective of the defense, including maintaining innocence. The Court found that defense counsel’s unilateral concession of guilt, despite the defendant’s insistence on innocence and without consultation, violated this right. The Court clarified that a defendant is not required to contemporaneously object to preserve this claim. The structural error required automatic reversal. The judgment of the Court of Appeals was reversed, the convictions vacated, and the case remanded for a new trial on all charges. View "People Of Michigan v. Klungle" on Justia Law

People Of Michigan v. Hess

2026-07-07T05:00:02-08:00

A woman pleaded guilty to third-degree retail fraud after stealing clothing from a store and was sentenced in the 64B District Court to probation under the Holmes Youthful Trainee Act. As a condition of probation, she was prohibited from using or possessing marijuana, although the court provided no specific justification for this restriction. During probation, she tested positive for marijuana twice, leading to probation violation charges. She then moved to amend her probation to permit marijuana use consistent with the Michigan Regulation and Taxation of Marihuana Act (MRTMA) and to vacate or dismiss her probation violations, arguing that the MRTMA protected such use. The district court denied her motion, found her in violation, revoked her youthful trainee status, and sentenced her to jail. On appeal, the Montcalm Circuit Court stayed her jail sentence but otherwise affirmed the lower court's decisions. The Michigan Court of Appeals also affirmed, reasoning that the probation act prohibits probationers from violating federal law, and since federal law criminalizes recreational marijuana, the act allowed—if not required—courts to prohibit MRTMA-compliant marijuana use as a probation condition. The Michigan Supreme Court reviewed the case and reversed the Court of Appeals. The Supreme Court held that a trial court may not prohibit MRTMA-compliant marijuana use as a probation condition solely because such use violates federal law. The Court explained that federal law does not preempt the MRTMA and that to the extent the probation act incorporates federal marijuana prohibitions, it is inconsistent with the MRTMA and does not apply to conduct permitted by the MRTMA. The Supreme Court remanded the case for the trial court to reconsider the defendant’s motions in light of this holding. View "People Of Michigan v. Hess" on Justia Law

US v. Fulcar

2026-07-06T13:00:04-08:00

The defendant was indicted by a federal grand jury in Massachusetts on three counts: being a prohibited person in possession of a firearm and ammunition, and two counts of possession with intent to distribute controlled substances. The first drug count was based on drugs found during his arrest, and the second on drugs found at his residence during a search. He moved to suppress evidence seized from his home, arguing the search violated the Fourth Amendment, but the district court denied the motion, finding the search was conducted under a valid warrant and in good faith. He also sought dismissal of the firearm charge, claiming the statute was unconstitutional under the Second Amendment, but that motion was denied. He then pleaded guilty to all counts. The United States District Court for the District of Massachusetts grouped the convictions for sentencing under the United States Sentencing Guidelines. The presentence report applied several enhancements, including one for being a career offender based on prior convictions. The defendant objected, arguing he had only one qualifying conviction and that a 2008 Massachusetts conviction for possession with intent to distribute cocaine should not count, because the definition of “controlled substance” had changed under federal law. The district court rejected his objections, but stated it would have imposed the same sentence even if it had accepted his arguments. The court ultimately imposed a below-Guidelines sentence of 96 months. The United States Court of Appeals for the First Circuit held that the district court erred in applying the career offender enhancement because the relevant Massachusetts conviction did not qualify as a “controlled substance offense” under the Guidelines at the time of federal sentencing, since the substance at issue was no longer federally controlled. Nevertheless, the error was harmless because the district court made clear it would have imposed the same sentence regardless. The court affirmed the convictions and sentences. View "US v. Fulcar" on Justia Law

US v. Rosado Maldonado

2026-07-06T13:00:04-08:00

Police officers in Worcester, Massachusetts, observed Joan Rosado Maldonado raise his arm before hearing a gunshot. Approaching the scene, they found Maldonado outside an apartment building and, upon searching him, discovered a loaded firearm in his satchel. Maldonado was indicted for being a prohibited person in possession of a firearm and ammunition under federal law. He pleaded guilty in March 2024. At sentencing, his prior convictions for trafficking in cocaine (2010) and possession with intent to distribute a Class B substance (2019), both under Massachusetts law, were considered in calculating his sentence. The United States District Court for the District of Massachusetts adopted the United States Probation Office's recommendation, assigning Maldonado a base offense level of twenty-four under the United States Sentencing Guidelines § 2K2.1(a)(2). This was based on the determination that his two prior convictions qualified as “controlled substance offenses.” The resulting guideline range was seventy to eighty-seven months’ imprisonment, and Maldonado was sentenced to sixty months in prison with three years of supervised release. The court also imposed various supervised release conditions, some of which Maldonado objected to, including restrictions on associating with persons possessing firearms. He timely appealed his sentence, arguing that his prior Massachusetts convictions did not categorically qualify as controlled substance offenses under federal law. The United States Court of Appeals for the First Circuit held that the term “controlled substance” in the relevant sentencing guideline refers only to substances regulated by the federal Controlled Substances Act, not by state law. Because Massachusetts included ioflupane as “cocaine” in its controlled substances list while federal law did not, Maldonado’s convictions were not a categorical match. The First Circuit vacated Maldonado’s sentence and remanded the case for resentencing. View "US v. Rosado Maldonado" on Justia Law

People v. Tyler

2026-07-06T11:03:29-08:00

In 1994, a jury found Reginald Tyler guilty of second degree murder. Many years later, California enacted Senate Bill No. 1437, which narrowed the scope of liability for murder and allowed those previously convicted under now-invalid theories to petition for resentencing. Tyler filed such a petition, asserting that under the revised law he was not guilty of murder as currently defined. The trial court found that Tyler had made a prima facie case for relief and scheduled an evidentiary hearing. At the hearing, the court heard testimony from expert witnesses and reviewed the trial record, including jury instructions and evidence relevant to Tyler’s state of mind and actions. The Superior Court of San Francisco City and County denied Tyler’s petition after the evidentiary hearing, concluding that the prosecution proved beyond a reasonable doubt that Tyler was guilty of second degree murder under current law. During the hearing, the trial court at times used the phrase “could be convicted” in discussing the applicable standard, but also repeatedly stated that it was required to determine, as an independent fact finder, whether Tyler was guilty beyond a reasonable doubt. Tyler appealed, arguing that the court had applied the wrong standard—focusing on whether he “could be convicted” rather than whether he was actually guilty beyond a reasonable doubt. The California Court of Appeal, First Appellate District, Division Four, affirmed the superior court’s decision. The appellate court held that, when viewed in context, the trial court correctly applied the reasonable doubt standard as an independent fact finder, rather than a substantial evidence or “could be convicted” standard. The court emphasized that the “could be convicted” language is not appropriate at the evidentiary hearing stage and clarified that the proper inquiry is whether the petitioner is guilty beyond a reasonable doubt under current law. View "People v. Tyler" on Justia Law

USA v Eta

2026-07-06T06:00:46-08:00

Federal authorities were investigating an individual suspected of orchestrating transnational cyber fraud and money laundering schemes originating in Nigeria and targeting U.S. nationals. Information from two sources, including a co-conspirator, implicated him as a leader of fraudulent operations. Investigators gathered corroborating evidence, such as suspicious messages, unusually high activity on messaging apps, and bank records showing millions in transactions with no apparent legitimate source. When authorities learned he would return to the U.S. from Nigeria, they requested a manual search of his electronic devices upon arrival at Atlanta’s international airport. Customs officers searched his phones, found evidence of criminal activity, and subsequently seized the devices for forensic imaging. Two days later, law enforcement obtained search warrants for the phones and their extracted data. The United States District Court for the Northern District of Illinois, Eastern Division, reviewed the defendant’s motion to suppress evidence from the warrantless border search of his cell phones, which he argued violated his Fourth Amendment rights. After an evidentiary hearing, the district court found law enforcement witnesses credible and denied the motion, concluding that the manual search at the border was justified under the border search doctrine. The defendant then entered a conditional guilty plea to wire fraud, preserving his right to appeal the suppression ruling. The United States Court of Appeals for the Seventh Circuit reviewed the district court’s denial de novo. The court reaffirmed that routine, manual searches of electronic devices at the border do not require a warrant or individualized suspicion under circuit precedent, specifically United States v. Mendez, and Supreme Court precedent. The court held that the search was routine, reasonable, and justified by the border search exception. Even if a Fourth Amendment violation occurred, the good-faith exception would preclude suppression. The judgment of the district court was affirmed. View "USA v Eta" on Justia Law

USA v. Carter

2026-07-06T05:02:05-08:00

The case concerns a defendant who pleaded guilty to possessing a firearm as a convicted felon, in violation of federal law. The defendant had four prior convictions under Georgia law for drug offenses involving cocaine, all committed on separate occasions. These prior convictions were used to classify him as an “armed career criminal,” triggering a mandatory minimum sentence of 15 years under the Armed Career Criminal Act (ACCA). The defendant did not dispute the existence of these convictions or that they occurred on different occasions. However, he argued that Georgia’s definition of cocaine is broader than the federal definition, contending that this difference should prevent his prior convictions from qualifying as ACCA predicate offenses. The United States District Court for the Middle District of Georgia overruled the defendant’s objection to the ACCA enhancement. The court concluded that the Georgia convictions counted as “serious drug offenses” under the ACCA and sentenced him to 210 months in prison. During sentencing, the court rejected arguments based on an expert’s declaration claiming a definitional mismatch between state and federal cocaine laws. Upon review, the United States Court of Appeals for the Eleventh Circuit considered whether Georgia law, by defining cocaine more broadly than federal law, rendered the prior convictions ineligible for ACCA enhancement. The appellate court held that for a substance to be a controlled substance under Georgia law, it must be listed on both Georgia and federal drug schedules. Thus, even if Georgia’s statutory language is broader, a conviction could not be based on conduct outside the federal definition. The court also rejected an argument based on changes to the federal schedules concerning “ioflupane.” The Eleventh Circuit affirmed the district court’s application of the ACCA enhancement. View "USA v. Carter" on Justia Law

State v. Rivera

2026-07-03T08:16:08-08:00

On the morning of September 25, 2021, Julio Castro saw Jorge Garcia, an acquaintance, at Roque’s Café in Providence, Rhode Island. Garcia was accompanied by his employer, Arturo Walker. Prior to this encounter, Juan Rivera, a friend of Castro, had inquired about Garcia, expressing an interest in discussing drugs with him. After a brief exchange at the café, Garcia was fatally shot by an individual captured on surveillance footage wearing a black sweatshirt with white lettering. Police determined the shooter arrived at the scene with another person in a red Toyota with a black hood and linked a black Dodge Ram at the scene to Rivera. Further investigation, including witness testimony and video evidence, implicated Rivera, who was later charged with multiple offenses including first-degree murder. After the incident, the Providence County Superior Court conducted a jury trial. The state introduced surveillance footage and other evidence, including statements from a now-deceased individual, Josue Calderon, and testimony from Isamarys Segura. Rivera’s defense objected to the admission of certain surveillance videos, argued hearsay exceptions were improperly applied to Calderon's statements, and challenged the admissibility of testimony about “the word on the streets.” The jury found Rivera guilty on all counts, and he was sentenced to two consecutive life terms plus additional concurrent sentences for the other offenses. The Supreme Court of Rhode Island reviewed the convictions. The court held that the trial justice did not abuse her discretion in admitting the surveillance footage, finding the foundation for authenticity under Rule 901 was sufficiently established through expert testimony. The court also determined that the defense failed to preserve objections to Calderon's statements and Segura’s testimony for appellate review, as contemporaneous objections were not made at trial. Accordingly, the court affirmed the Superior Court’s judgment. View "State v. Rivera" on Justia Law

Allen v. The State of Nevada

2026-07-03T08:07:42-08:00

A 12-year-old girl was sexually assaulted in her bedroom while living with her parents and half-brother, A.S., who was 21 at the time. The victim identified her father, who stayed in a guest house but had access to the main home, as the perpetrator. The father maintained his innocence and pursued a defense theory that A.S., the victim’s half-brother, was the true perpetrator. To support this alternative-suspect defense, the father sought access to juvenile records showing that A.S. had previously committed a similar sexual offense against a stepsibling when he was a minor. The Eighth Judicial District Court, Clark County, initially agreed to review A.S.’s juvenile records in camera to determine if any should be disclosed. However, after several judicial transfers, the second judge reviewed the records and summarily found nothing relevant or material, denying their release. A subsequent motion to reconsider was also denied by a third judge, who did not review the records. At trial, evidence of A.S.’s prior offense was excluded, and the jury convicted the father on all charges of sexual assault with a minor under 14 and lewdness with a child under 14. The defense’s alternative suspect theory was presented to the jury, but without the excluded evidence of A.S.’s prior misconduct. The Supreme Court of the State of Nevada reviewed the case and held that the district court abused its discretion by finding A.S.’s prior sexual offense irrelevant. The Supreme Court found that this evidence was relevant to the defense’s alternative-suspect theory and that its exclusion was not harmless, as it foreclosed further investigation and may have affected the verdict. The Supreme Court reversed the conviction and remanded the case for a new trial. View "Allen v. The State of Nevada" on Justia Law

State v. Nahulu

2026-07-02T12:33:35-08:00

After a late-night police pursuit in Makaha, a white Honda being followed by several Honolulu Police Department officers crashed, causing severe injuries to its young occupants. Officer Joshua Nahulu was alleged to have driven the lead pursuit vehicle, with officers Erik Smith, Jake Ryan Bartolome, and Robert Gus Lewis III following. Witness accounts conflicted on whether police vehicles made physical contact with the Honda. However, an expert found no evidence of such contact. None of the officers stopped to render aid after the crash, and they only returned after other emergency responders had arrived. Nahulu was charged under Hawaiʻi’s “fled scene” statute, which requires a driver “involved in a collision” resulting in serious injury or death to stop and render aid. His co-defendants were charged with hindering prosecution and conspiracy. The Circuit Court of the First Circuit denied the defendants’ motions to dismiss, finding the statute’s language—specifically, “involved in a collision”—was not unconstitutionally vague and that the defendants had sufficient notice of the charges. The court ordered the State to clarify, through a bill of particulars, whether it alleged physical contact between Nahulu’s vehicle and the Honda; the State responded that it did not rely on such a theory. On appeal, the Supreme Court of the State of Hawaiʻi held that Nahulu could only challenge the statute as vague as applied to his conduct, not on its face, since the law does not implicate constitutional rights such as free speech. The court further held that “involved in a collision” is not unconstitutionally vague as applied to Nahulu and that the combination of the charging instrument and the bill of particulars provided sufficient notice of the nature and cause of the accusation. The Supreme Court affirmed the circuit court’s denial of the motions to dismiss. View "State v. Nahulu" on Justia Law

In re Melson

2026-07-02T11:03:27-08:00

The case centers on a defendant charged with multiple crimes stemming from a fatal gang-related shooting in Watts, Los Angeles. Two eyewitnesses, one from inside the victim’s car and another from a nearby house, identified the defendant as the shooter or as fleeing the scene. Their identification was primarily based on a photo lineup and their testimony at trial. The first trial ended in a hung jury, but during the retrial, both witnesses added new details, claiming to have told police about key identifying features or sightings soon after the shooting. These statements were contradicted by police interview transcripts, which were not presented at trial. Following the retrial, the defendant was convicted of murder, attempted murder, shooting at an occupied vehicle, and possession of a firearm by a felon. On direct appeal, one attempted murder conviction was reversed, but the rest of the judgment was affirmed by the California Court of Appeal. The defendant filed a habeas corpus petition, alleging that the prosecution allowed false testimony and that his trial counsel was ineffective for failing to impeach the witnesses. The Los Angeles County Superior Court denied the petition after an evidentiary hearing, finding the witnesses’ statements to be merely inconsistent, not false. The California Supreme Court then ordered the Court of Appeal to reconsider the habeas petition. The California Court of Appeal, Second Appellate District, reviewed the petition and found that the prosecution failed its constitutional duty to correct false testimony from its witnesses, and defense counsel’s lack of preparation contributed to the use of false evidence. Applying the materiality standard from Napue v. Illinois and Glossip v. Oklahoma, the court held that the People did not prove beyond a reasonable doubt that the false testimony did not contribute to the conviction. The court granted the writ of habeas corpus, vacated the conviction, and remanded the case for further proceedings. View "In re Melson" on Justia Law

United States v. Harrell

2026-07-02T11:00:46-08:00

The defendant served in the military and received disability-related unemployability benefits from the Department of Veterans Affairs, which required recipients to notify the VA if they became employable. After founding a nonprofit in 2019 and working full-time, the defendant did not report his employment to the VA and continued receiving benefits. He was indicted for theft of government funds under 18 U.S.C. § 641, with a jury later convicting him. The indictment included notice of possible criminal forfeiture. In the United States District Court for the Eastern District of Kentucky, the government moved for a preliminary order of forfeiture before sentencing, but the court did not address it. At sentencing, the court imposed prison time, supervised release, and restitution, but did not orally address forfeiture. The court allowed the defendant to file supplemental briefing after sentencing. Following the hearing, the district court issued several written judgments and amended judgments, none of which initially included forfeiture. The government repeatedly moved to amend the judgment to include forfeiture. Eventually, the district court issued an order imposing forfeiture and amended the judgment to reflect this, several months after sentencing. The defendant appealed, arguing errors in the handling of forfeiture under Federal Rule of Criminal Procedure 32.2 and violations of his right to presence under Rule 43(a) and the Due Process Clause. The United States Court of Appeals for the Sixth Circuit held that, although the district court violated Rule 32.2(b)(4)(B) by failing to impose forfeiture at sentencing and to include it in the judgment, this rule is a time-related directive subject to harmless-error review. The error was harmless because the defendant had notice and opportunity to contest forfeiture. The court also found no violation of the defendant’s due process right to presence, and although Rule 43(a) was violated, it did not affect substantial rights. The oral sentence and written judgment were not in conflict. The court affirmed the district court’s judgment. View "United States v. Harrell" on Justia Law

US v. Covington

2026-07-02T10:30:51-08:00

W.W., an incarcerated person, died after experiencing a severe medical crisis while in Bureau of Prisons custody. Shronda Covington was the highest-ranking official on duty at the time and had the authority to call a physician or send W.W. to the hospital; evidence showed that she was informed of W.W.’s distress but allegedly failed to intervene. Tonya Farley, a BOP nurse, examined W.W., observed troubling symptoms, but instead of seeking appropriate medical attention, contacted a psychologist and submitted a report stating no signs of acute distress. Both Covington and Farley later made statements to investigators that were allegedly false regarding their actions during the crisis. After an investigation, Covington and Farley were charged in the United States District Court for the Eastern District of Virginia. Covington was convicted by a jury of violating 18 U.S.C. § 242 (willfully depriving W.W. of his constitutional rights, with the jury finding bodily injury but not death resulted), as well as making false statements under 18 U.S.C. § 1001. Farley was convicted of making false statements under 18 U.S.C. § 1001 but acquitted of the Section 242 charge and another false report charge. Both defendants were sentenced to terms of incarceration and home detention. Farley contested the inclusion of her acquitted conduct in calculating her Guidelines range. The United States Court of Appeals for the Fourth Circuit reviewed the case. The court held that Section 242’s “bodily injury results from” language requires proof of both but-for and proximate causation. The district court erred by not instructing the jury on proximate cause for Covington’s Section 242 conviction, so that conviction and both defendants’ sentences were vacated and remanded for further proceedings. The court affirmed both defendants’ convictions for making false statements under Section 1001, rejecting all other challenges. View "US v. Covington" on Justia Law

Langford v. Stonebreaker

2026-07-02T10:30:50-08:00

After a robbery at a Chinese restaurant owner’s home in South Carolina, three masked men assaulted the family and stole their earnings. The victims could not identify the attackers, and no forensic evidence was left behind. Weeks later, a tip led investigators to three suspects, including K.C. Langford, who was arrested and indicted along with two co-defendants. Langford’s trial was delayed for nearly two years, partly due to difficulties in securing an interpreter for the victims and because one co-defendant, Alvin, initially refused to testify after being pressured by Langford and another defendant. The trial eventually proceeded, with Alvin testifying against Langford. Langford was convicted of criminal conspiracy, armed robbery, first-degree burglary, and kidnapping. After conviction, Langford appealed to the South Carolina Supreme Court, which affirmed his convictions. The court found that although the prosecutor’s control over the trial docket violated the state constitution, Langford suffered no prejudice from it. Applying the Barker v. Wingo framework, the court determined the nearly two-year delay did not violate Langford’s Sixth Amendment right to a speedy trial, considering the reasons for the delay and lack of prejudice to Langford’s defense. Langford’s postconviction relief application in the Court of Common Pleas was denied, as the court found no ineffective assistance of counsel regarding a hearsay issue in the trial. The South Carolina Court of Appeals denied certiorari. Langford’s co-defendant, Bryan, received postconviction relief in a separate proceeding. Langford then sought federal habeas corpus relief in the United States District Court for the District of South Carolina, which granted the writ on claims of speedy trial violation and ineffective assistance of counsel. The United States Court of Appeals for the Fourth Circuit reversed, holding that the South Carolina courts’ decisions were not unreasonable applications of clearly established federal law nor based on unreasonable factual determinations. The Fourth Circuit ordered reversal of the district court’s grant of habeas corpus. View "Langford v. Stonebreaker" on Justia Law

USA v. Kendall

2026-07-02T09:30:55-08:00

The defendant pled guilty to possession of a firearm and ammunition by a convicted felon and was sentenced to eighteen months in prison followed by three years of supervised release. The district court imposed standard and special conditions of supervised release, including substance abuse treatment and a battering intervention program. After serving his prison term, the defendant began supervised release but soon violated two conditions: refusing substance abuse treatment and threatening his probation officer. At a hearing, he admitted to these violations, and the district court revoked his supervised release, sentencing him to six months in custody and thirty months of supervised release with new conditions, including home detention and location monitoring. The United States District Court for the Southern District of Texas issued the revocation judgment, which the defendant appealed, arguing that several conditions of supervised release conflicted with the oral pronouncement at sentencing. During the appeal, his supervised release was revoked again for failing to participate in location monitoring and for not following probation officer instructions. The district court imposed a new custodial sentence and another term of supervised release with similar conditions, except for the removal of the mental health treatment requirement. The United States Court of Appeals for the Fifth Circuit found the appeal largely moot due to the superseding revocation, except for conditions that were the basis of the second revocation. The Fifth Circuit held that only the home detention special condition and the requirement to follow probation officer instructions remained live issues and were improperly pronounced at sentencing because the defendant had not been given notice or an opportunity to object. The court vacated the judgment in part, remanded for amendment to remove those conditions, and dismissed the challenge to other conditions as moot. View "USA v. Kendall" on Justia Law

People v. Espino

2026-07-02T09:02:46-08:00

The defendant was charged with several robberies and related offenses, and the prosecution alleged that he had previously served a prison term under former Penal Code section 667.5(b). The defendant pleaded no contest, admitting the prior prison term allegation. At sentencing in 2017, the Santa Clara County Superior Court found the prior prison term allegation true but exercised its discretion to strike the punishment for the enhancement in the interest of justice, without striking the allegation itself. The abstract of judgment reflected the true finding. After the Legislature enacted Penal Code section 1172.75, which retroactively invalidated most prior prison term enhancements imposed before January 1, 2020, the defendant petitioned for resentencing. The Santa Clara County Superior Court denied the petition, concluding that section 1172.75 applied only to persons for whom a section 667.5(b) enhancement was imposed and executed, not to those for whom the enhancement was stayed, stricken, or dismissed. On appeal, the Sixth District Court of Appeal reversed the superior court’s decision, holding that section 1172.75 applies whenever a prior prison term enhancement was imposed, regardless of whether the punishment was executed, stayed, or struck. A dissenting opinion argued that a punishment-stricken enhancement is not “imposed” under section 1172.75(a) because it does not lengthen a defendant’s sentence. The Supreme Court of California granted review and addressed whether section 1172.75(a) invalidates a prior prison term enhancement for which punishment was stricken. The Court held that an enhancement is “imposed” when it is made part of a legally effective sentencing order, even if the punishment is stricken. Consequently, the defendant is entitled to resentencing under section 1172.75. The Supreme Court of California affirmed the judgment of the Court of Appeal. View "People v. Espino" on Justia Law

USA v Rose

2026-07-02T09:01:19-08:00

In 2009, Jonathan Rose was involuntarily committed to a mental institution in Indiana due to a psychiatric disorder, though the specific diagnosis and its severity were not detailed in the record. He was released in early 2010 and has not been recommitted since. In 2022, Rose successfully purchased multiple firearms, though he was denied others after background checks revealed his prior commitment. In 2023, he was indicted under federal law for possessing firearms as a person previously committed to a mental institution and for making false statements to firearms dealers by denying his commitment history. The United States District Court for the Northern District of Indiana reviewed Rose’s case and dismissed the counts related to possession of firearms by a previously committed person under 18 U.S.C. §922(g)(4). The district court reasoned that this statute, as applied to someone no longer suffering from mental illness, was inconsistent with the Second Amendment, particularly in light of recent Supreme Court decisions emphasizing individualized assessments of current danger rather than permanent disabilities based on past conditions. The United States Court of Appeals for the Seventh Circuit considered the government’s appeal. The court determined that the district court should not have dismissed the indictment without an evidentiary hearing to assess Rose’s current mental health and dangerousness. The Seventh Circuit held that, after recent Supreme Court decisions, the constitutionality of §922(g)(4) as applied depends on whether the defendant currently poses a credible threat to the safety of others. Because the record lacked evidence concerning Rose’s present mental condition, the appellate court vacated the district court’s order and remanded for further proceedings to develop the necessary facts. View "USA v Rose" on Justia Law

USA v. SHI

2026-07-02T08:01:10-08:00

Three individuals participated over the course of a year in a complex money laundering operation involving Target gift cards. These cards were obtained through telephone scams, with victims deceived into purchasing the cards and providing the card numbers and access codes to overseas scammers. The defendants received these codes through encrypted messaging, then employed “runners” to quickly use the cards at Target stores—often buying high-value electronics or transferring balances to new gift cards. The merchandise was resold, and most of the proceeds were sent back to the scam’s organizers in China after taking a cut for themselves. One defendant continued to participate in the conspiracy even after being arrested and released on bond. The United States District Court for the Central District of California presided over their trial. A jury convicted all three of conspiracy to commit money laundering, with one also convicted for continuing the conspiracy while on pretrial release. At sentencing, the district court adopted the presentence reports, calculated the offense levels based on the scope and nature of their conduct, and applied several enhancements, including those for the amount laundered, sophisticated laundering, aggravated roles, and for being in the business of laundering funds. The court sentenced the defendants to terms below the calculated Guidelines range, but above the mandatory minimums. The United States Court of Appeals for the Ninth Circuit reviewed the case. The court affirmed the district court’s calculation of the loss amount and its application of aggravated and minor role adjustments. However, the appellate court held that the district court erred in applying a two-level enhancement for sophisticated laundering; under the Sentencing Guidelines, this enhancement can only be imposed if a different, specific enhancement was also applied, which did not occur here. The sentences were therefore vacated in part and remanded for limited resentencing to correct the guideline computation. View "USA v. SHI" on Justia Law

State v. Wright

2026-07-02T07:35:10-08:00

The case centers on a criminal defendant who, during the course of prosecution, requested that the state provide him with copies of discovery materials at no cost. The defendant argued that he was entitled to free copies under Oregon’s criminal discovery statutes. The state refused, maintaining that its obligation was limited to providing access to the materials, not free copies. After the circuit court denied the defendant’s motion to compel the state to provide the copies without cost, the defendant sought a writ of mandamus from the Supreme Court of Oregon. After the defendant petitioned for mandamus relief, the Supreme Court of Oregon issued an alternative writ, directing the circuit court to either vacate its order or show cause for not doing so. Subsequently, the state provided the requested discovery materials at no cost and moved the circuit court to vacate its prior order, which the circuit court granted. The state then asked the Supreme Court of Oregon to dismiss the mandamus proceeding as moot, but the court initially allowed briefing and argument to proceed, recognizing that the underlying issue was capable of repetition yet likely to evade judicial review. Upon further examination, the Supreme Court of Oregon determined that the defendant’s principal argument relied on the amended definition of “disclose” in ORS 135.805(2), as revised by a 2021 statute. However, the court found that this amended statute applies only to offenses alleged to have occurred on or after January 1, 2022, while the defendant’s charges concerned conduct occurring prior to that date. Because the statutory amendment did not apply to the defendant’s case, and his main argument rested on that amendment, the court exercised its discretion not to adjudicate the moot mandamus petition and dismissed the alternative writ. View "State v. Wright" on Justia Law

McInnis v. Bolin

2026-07-02T07:30:58-08:00

Jquan Leearthur McInnis, then a juvenile, shot and killed Gustav Christianson and an infant, J.R., by firing seven shots into a car in downtown Minneapolis. Evidence gathered by investigators included statements made by McInnis to associates and forensic evidence showing the sequence of shots. After being apprehended and advised of his Miranda rights, McInnis initially denied involvement but eventually confessed to the shootings after invoking his right to remain silent. He maintained that he did not intend to kill Christianson and was unaware of the infant’s presence. The case was tried in a Minnesota state court, where McInnis moved to suppress his confession, arguing it was obtained after he had invoked his Fifth Amendment rights. The trial court denied the motion, concluding that McInnis had not unequivocally invoked his right to remain silent. The trial proceeded on stipulated evidence, including the confession, and McInnis was convicted of two counts of first-degree murder and sentenced to two consecutive life terms with the possibility of parole. On appeal, the Minnesota Supreme Court agreed that the confession should have been suppressed but determined that its admission was harmless beyond a reasonable doubt, given the other overwhelming evidence of guilt. McInnis then sought a writ of habeas corpus from the United States District Court for the District of Minnesota, arguing that the Minnesota Supreme Court unreasonably applied federal law on harmless error. The district court denied relief but granted a certificate of appealability on the harmless error issue. On appeal, the United States Court of Appeals for the Eighth Circuit held that McInnis failed to show that the Minnesota Supreme Court’s harmless error determination was contrary to or an unreasonable application of clearly established federal law. The Eighth Circuit affirmed the district court’s denial of the habeas petition. View "McInnis v. Bolin" on Justia Law

Rhodes v. State of Florida

2026-07-02T07:04:28-08:00

The appellant was convicted of first-degree murder and sentenced to death after the body of Karen Nieradka was found in construction debris several weeks after her disappearance. He was arrested while driving Nieradka’s vehicle and made various conflicting statements to law enforcement. At trial, several jailhouse witnesses, including Edward Cottrell and Harvey Duranseau, testified that the appellant made incriminating statements. He was convicted and sentenced to death, with both his conviction and sentence affirmed on direct appeal. Subsequent postconviction motions were denied. After filing a successive motion for postconviction relief in the Circuit Court for Pinellas County, the appellant presented affidavits from Cottrell and Duranseau alleging that they were coached by law enforcement and offered benefits in exchange for their testimony. Additional affidavits claimed law enforcement fabricated police reports. The postconviction court held an evidentiary hearing, hearing testimony from both jailhouse witnesses and law enforcement. The postconviction court found that the jailhouse witnesses were not credible and denied all relief, including rehearing. On appeal, the Supreme Court of Florida reviewed four claims: violations under Brady v. Maryland and Giglio v. United States, improper elicitation of statements under Massiah v. United States, and newly discovered evidence. The Court deferred to the postconviction court’s credibility determinations, finding competent, substantial evidence supported those findings. The Court held that the appellant failed to establish suppression of material exculpatory evidence, the use of false testimony, the existence of state agents violating his right to counsel, or newly discovered evidence warranting a new trial. The Supreme Court of Florida affirmed the Circuit Court’s denial of the successive motion for postconviction relief. View "Rhodes v. State of Florida" on Justia Law

D.W. v. United States

2026-07-02T06:33:34-08:00

One afternoon, a group of seven individuals, including the appellant, were standing near a breezeway at an apartment complex in Southeast Washington, D.C. Police officers, who were on routine patrol and not responding to any specific report of criminal activity, stopped near the complex and began approaching the group from about 100 feet away. Upon noticing the officers, the appellant and another man immediately fled at a full sprint through the complex. The officers pursued the appellant, who led them on a chase over fences and through yards, ultimately dropping a firearm as he was apprehended. The police recovered the weapon, and the appellant was charged with several firearm-related offenses. The case was first reviewed by the Superior Court of the District of Columbia. At a suppression hearing, the appellant moved to exclude the gun, arguing the officers lacked reasonable suspicion for his seizure. The trial court found that the seizure occurred when an officer grabbed the appellant’s leg as he attempted to scale a second fence. The court concluded that the officers had reasonable articulable suspicion to justify the seizure, relying on the appellant’s immediate flight upon seeing police, the extended and desperate nature of the chase, and testimony that the apartment complex was a high-crime area. The appellant was convicted at a stipulated trial after the suppression motion was denied. On appeal, a panel of the District of Columbia Court of Appeals vacated the convictions, finding an absence of reasonable suspicion. The court then granted en banc rehearing and vacated the panel’s opinion. The en banc District of Columbia Court of Appeals held that, under the totality of the circumstances, the officers had reasonable articulable suspicion to seize the appellant, primarily due to his unprovoked flight upon seeing police, the particularized testimony about crime at the complex, and the desperation evident in his flight. The court affirmed the convictions. View "D.W. v. United States" on Justia Law

Perry v. United States

2026-07-02T06:33:33-08:00

Two women were attacked late at night near the U Street Metro station by a group, including a woman with blonde braids and grey leggings. The victims, Walton and Reynolds, confronted the group to stop fighting, which led to the woman with blonde braids initiating an assault. Walton was knocked unconscious and both women were beaten. Afterward, Walton described her attacker to police and later received an Instagram video depicting the incident. Eight months later, Perry was arrested and charged with two counts of simple assault, allegedly as the principal instigator in the group attack. No pre-arrest identification procedures were conducted by law enforcement. At the Superior Court of the District of Columbia, Perry moved to exclude the Instagram video and any in-court identification based on it, arguing insufficient authentication and reliability. The court denied these motions, permitting the government to introduce the video authenticated by Walton’s testimony and allowing Walton’s in-court identification. After viewing the video and hearing testimony, the court found Perry guilty of both assaults. Perry was sentenced to jail and ordered to pay over $6,000 in restitution for Walton’s medical bills and lost wages. Defense counsel initially objected to the restitution amount's documentation, but after reviewing supporting documents, did not contest the amount further. The District of Columbia Court of Appeals reviewed Perry’s challenges to the video’s admission, the identification, and the restitution order. The court held that the Instagram video was properly authenticated by Walton’s firsthand testimony, did not violate the best evidence rule, was not hearsay, and did not implicate the Confrontation Clause. Walton’s in-court identification was deemed reliable under the circumstances. The restitution order was upheld as factually supported and not based on an impermissible uniform policy. The District of Columbia Court of Appeals affirmed Perry’s convictions and restitution order. View "Perry v. United States" on Justia Law

USA v. Adefusi

2026-07-02T06:30:59-08:00

Babajide Adefusi entered a plea agreement with the United States Attorney’s Office for the Southern District of Texas in 2018, pleading guilty to aiding and abetting passport fraud. The scheme involved using counterfeit passports with Adefusi’s photo and false identity information to open bank accounts, into which funds from internet scam victims were wired. The total loss from the passport fraud scheme was approximately $2.2 million. The plea agreement included a promise by the “United States” not to pursue additional charges arising out of the scheme alleged in the charging document. The agreement, however, specified that it bound only the U.S. Attorney’s Office for the Southern District of Texas and not any other U.S. Attorney. After completing his sentence, Adefusi was indicted by a federal grand jury in the Central District of Illinois in 2023 for conspiring to commit wire fraud related to a scheme defrauding E-MedRx, a pharmacy billing company. Adefusi moved to dismiss the indictment, arguing that the earlier plea agreement barred the Central District of Illinois from prosecuting him due to factual overlap between the two schemes. The United States District Court for the Central District of Illinois denied the motion, finding the plea agreement unambiguously bound only the Southern District of Texas office. The United States Court of Appeals for the Seventh Circuit reviewed the district court’s denial of Adefusi’s motion to dismiss. Applying principles of contract interpretation to the plea agreement, the Seventh Circuit held that the agreement unambiguously bound only the U.S. Attorney’s Office for the Southern District of Texas and not other U.S. Attorney’s Offices. Thus, the Central District of Illinois was not barred from prosecuting Adefusi for wire fraud conspiracy. The Seventh Circuit affirmed the district court’s decision. View "USA v. Adefusi" on Justia Law

MONTGOMERY v. STATE OF TEXAS

2026-07-02T04:46:56-08:00

The appellant was charged in two separate cases with theft from a person and evading arrest with a vehicle. He pled guilty to both charges and received deferred adjudication for ten years as part of a plea agreement, which also resulted in the State not pursuing habitual-offender enhancement. After being arrested for additional offenses, the State filed a petition to proceed to adjudication, alleging violations of the appellant’s community supervision, which was later amended to include further infractions. The appellant objected to the hearing being conducted virtually, citing concerns under the Due Process and Equal Protection Clauses as well as the Confrontation Clause. The trial court in Tarrant County held the hearing via Zoom, overruled the appellant’s objections, and adjudicated him guilty of both offenses, revoking his probation. The appellant filed motions for a new trial and notices of appeal, which were denied. On appeal to the Second Court of Appeals, he argued that the virtual hearing violated his rights under the Confrontation Clause and the Fourteenth Amendment. The appellate court found that the virtual hearing did not significantly impair his participation and concluded there was no violation of Due Process. It further held that the Confrontation Clause did not apply to revocation proceedings, reasoning that these are not criminal prosecutions as contemplated by the Sixth Amendment, and affirmed the trial court’s rulings. Upon review, the Court of Criminal Appeals of Texas considered only the Confrontation Clause issue. The court held that the Confrontation Clause does not apply to hearings on motions to enter adjudication of guilt and probation revocation, as such proceedings are not criminal prosecutions under the Sixth Amendment. Accordingly, the court affirmed the judgment of the Second Court of Appeals. View "MONTGOMERY v. STATE OF TEXAS" on Justia Law

United States v. Shelton

2026-07-01T13:00:39-08:00

A Michigan physician was charged with twenty-one counts of unlawfully distributing controlled substances to his patients. Over several years, he prescribed large quantities of medications to individuals who exhibited signs of drug-seeking behavior, failed drug screens, engaged in doctor shopping, and requested specific highly abused drugs. The physician often ignored red flags such as patients’ substance abuse histories and failed to perform required physical examinations. His practices led to at least one patient’s overdose death. Evidence at trial included expert testimony that his prescribing was inappropriate and outside the usual course of professional practice. The case was first tried in the United States District Court for the Eastern District of Michigan, but the initial trial ended in a mistrial. A retrial was delayed and declared a mistrial due to the COVID-19 pandemic. The third trial proceeded in March 2023, with the district court requiring witnesses to wear masks while testifying. After a 13-day trial, a jury convicted the physician on all counts. Post-trial motions for acquittal or a new trial were denied, and the physician was sentenced to twenty years on the count involving death, with concurrent sentences on the remaining counts. He appealed, challenging the sufficiency of the evidence, the authority of the Attorney General to regulate prescribing, the jury instructions, and the mask mandate’s constitutionality. The United States Court of Appeals for the Sixth Circuit reviewed the appeal. It held that sufficient evidence supported the convictions, the jury instructions accurately reflected the law and were not misleading or confusing, and the district court’s mask mandate did not constitute reversible error under the Confrontation Clause. The court found no plain error in the regulatory and constitutional challenges and affirmed the district court’s judgment in its entirety. View "United States v. Shelton" on Justia Law

United States v. Sago

2026-07-01T12:31:52-08:00

Kyle Quentin Sago shot and killed Daniel Morgan, who was unarmed, after returning to Morgan’s residence in Tulsa, Oklahoma. Sago admitted to the shooting during his testimony at trial, stating he acted out of fear. Initially, Sago entered into a plea agreement to plead guilty to second-degree murder, but the district court rejected the plea after determining the facts met the requirements for premeditated first-degree murder. Sago subsequently withdrew his guilty plea and proceeded to trial, where he was charged with multiple counts, including first-degree murder, felon in possession of ammunition, and causing death with a firearm. At trial, Sago’s counsel conceded Sago was the shooter and focused on contesting premeditation, seeking a conviction for second-degree rather than first-degree murder. Sago testified, admitted to the shooting and prior felonies, and the jury convicted him on all counts. After sentencing, Sago appealed directly to the United States Court of Appeals for the Tenth Circuit, which affirmed his convictions and sentence. The appellate court found no error in the district court’s refusal to instruct on imperfect self-defense and determined there was sufficient evidence supporting the jury’s verdict. Sago then filed a motion in the United States District Court for the Northern District of Oklahoma under 28 U.S.C. § 2255, asserting ineffective assistance of counsel. The district court denied his motion, holding that his counsel did not fail to subject the prosecution’s case to adversarial testing and that Sago did not meet the Strickland standard for ineffective assistance. The United States Court of Appeals for the Tenth Circuit reviewed the denial of Sago’s § 2255 motion. The court held that neither structural error under McCoy v. Louisiana nor presumed prejudice under United States v. Cronic applied because Sago did not object contemporaneously to his counsel’s strategy and counsel did not entirely fail to contest guilt. The court affirmed the district court’s denial of Sago’s motion. View "United States v. Sago" on Justia Law

People v. Castro

2026-07-01T12:03:04-08:00

The case concerns a late-night car crash in Bloomington, San Bernardino County, where Steven Richard Castro collided with a parked vehicle, injuring its occupant. Neighbors restrained Castro, who tried to flee, and emergency personnel transported him to the hospital due to his combative behavior. CHP Officer Pope, stationed at the hospital on another matter, was notified about Castro's arrival and subsequently observed Castro sedated and unresponsive in the ER. Pope noted the smell of alcohol and, after gathering information from witnesses and the victim, arrested Castro on suspicion of DUI causing injury. Without seeking a warrant, Pope ordered a blood draw, relying on implied consent law. The blood test showed a high BAC. In the San Bernardino County Superior Court, Castro moved to suppress the blood test results, arguing that a warrant should have been obtained. The magistrate denied the motion, citing exigent circumstances per Mitchell v. Wisconsin, reasoning that Officer Pope’s time in the hospital justified the warrantless blood draw. Castro renewed his suppression request in a pretrial motion, but the court again found the officers’ actions constitutional based on the totality of circumstances and Castro’s unconsciousness, leading Castro to enter a no contest plea. The California Court of Appeal, Fourth Appellate District, Division One, reviewed the case. The court held that the record did not support a finding of exigency sufficient to excuse the failure to obtain a warrant for the blood draw. The court emphasized that Mitchell v. Wisconsin does not create a categorical rule for unconscious DUI suspects and, following its reasoning in People v. Alvarez, found no evidence that obtaining a warrant would have interfered with other pressing duties. The judgment was reversed, and the matter remanded with directions to grant the suppression motion and permit Castro to withdraw his plea. View "People v. Castro" on Justia Law

CLARK v. THE STATE

2026-07-01T10:30:53-08:00

A man was convicted for malice murder and related offenses stemming from a murder-for-hire scheme in 2000, where the victim was killed in her Georgia apartment. The prosecution argued that the murder was orchestrated by the victim’s father-in-law, who opposed her marriage, and that the appellant was the hired killer, with testimony from accomplices and witnesses supporting this theory. The appellant's trial was marked by difficulties in securing expert witnesses and conducting mitigation investigations due to funding shortfalls in Georgia’s indigent defense system, which hampered his defense’s ability to prepare. Eventually, he was convicted on several counts and initially sentenced to death, with subsequent modifications after further proceedings. After conviction, the appellant’s attorneys from the Capitol Defender’s Office filed a motion for a new trial, later amended and supplemented by other attorneys from the same office. The Superior Court of Fulton County partially granted the motion, ordering a new trial solely on the issue of “mental retardation” for sentencing purposes, due to the late development of evidence related to this issue, which was attributed to a breakdown in indigent defense funding. Later, a new judge re-sentenced the appellant to life without parole in accordance with that order. Other grounds for a new trial were denied, and the appellant retained private counsel to pursue his appeal. The Supreme Court of Georgia reviewed the case and determined that, because this appeal was the appellant’s first opportunity to raise ineffective assistance of counsel claims (having been continuously represented by the same public defender’s office), the record was insufficiently developed on this issue. The Court vacated the trial court’s judgment in part and remanded the case for an evidentiary hearing on the ineffective assistance claims. Other claims regarding denial of a continuance and competency to stand trial were rejected, as the appellant failed to show harm or preserve those issues. Judgment was affirmed in part and vacated and remanded in part. View "CLARK v. THE STATE" on Justia Law

US v. Holley

2026-07-01T10:30:24-08:00

Brad Acy Holley, who was serving a 127-month federal sentence after pleading guilty to methamphetamine conspiracy, suffered from significant health issues, including polycystic kidney disease and end-stage renal disease requiring dialysis. Following his declining health and ongoing treatments in a federal medical facility, Holley sought compassionate release, arguing that his condition constituted an extraordinary and compelling reason for a sentence reduction. He also asserted that he was not receiving necessary specialized medical care in prison, particularly a kidney transplant, and requested appointment of counsel and an expert witness to assist with his motion. The United States District Court for the Southern District of West Virginia denied Holley’s requests, finding that his medical condition, while serious, was being adequately managed in prison and did not qualify as a terminal illness or otherwise meet the threshold for extraordinary and compelling reasons for compassionate release. The court also declined to appoint counsel or an expert, determining that neither was warranted under the circumstances. Holley appealed these decisions. The United States Court of Appeals for the Fourth Circuit reviewed the district court’s decisions for abuse of discretion. The appellate court held that the district court did not abuse its discretion in denying compassionate release, finding the court properly relied on Holley’s individualized medical records rather than generalized statistics, and reasonably concluded Holley was not suffering from a terminal illness with an end-of-life trajectory. The Fourth Circuit also held that Holley was not legally entitled to appointed counsel or an expert witness for his compassionate release motion, as there were no exceptional circumstances justifying such appointments. Accordingly, the Fourth Circuit affirmed the district court’s judgment in all respects. View "US v. Holley" on Justia Law

MILLER v. THE STATE

2026-07-01T10:13:05-08:00

The case involves a defendant who was convicted of malice murder and other related crimes following the fatal shooting of a convenience store owner late at night. Surveillance footage captured the movements of three assailants before and after the shooting, and law enforcement linked the defendant to the crime through evidence including a matching vehicle, clothing, cell phone records, and an anonymous tip. During the investigation, police obtained multiple search warrants that led to the seizure of various pieces of evidence, such as cell phones and ammunition. The defendant challenged the legitimacy of these warrants, arguing that the affidavits supporting them included material misrepresentations and omissions by police. After being indicted and tried in the Superior Court of DeKalb County, the defendant was convicted on all counts and sentenced to life imprisonment without parole for malice murder, with additional consecutive sentences for other offenses. The trial court merged some counts and vacated others as required by law. The defendant moved for a new trial, which was denied after a hearing. He then appealed, arguing that the trial court erred in denying his motion to suppress evidence due to alleged false statements in the search warrant affidavits and that his right to confront witnesses was violated by the admission of substitute expert testimony. The Supreme Court of Georgia reviewed the case. The court held that the trial court had not properly applied the standard from Franks v. Delaware for assessing whether false statements in warrant affidavits were made knowingly, intentionally, or with reckless disregard for the truth. The Supreme Court of Georgia vacated the trial court’s judgment on the motion to suppress and remanded the case for further proceedings consistent with the proper Franks analysis, leaving other issues unresolved pending that review. View "MILLER v. THE STATE" on Justia Law

USA v. Rosario

2026-07-01T09:00:13-08:00

A man with previous felony drug convictions sold drugs to an individual named Correa at a Pennsylvania gas station. Later that day, Correa was found dead in his car, with toxicology revealing fentanyl-laced heroin and cocaine in his system. An investigation uncovered that Correa had arranged the transaction with the man through text messages and Facebook Messenger, and security footage confirmed their meeting. The man admitted to supplying cocaine but denied selling heroin. A search warrant was obtained for the man’s Facebook records, leading to the discovery of extensive drug-related communications, including evidence of a gun-for-drugs exchange. A federal grand jury indicted the man on multiple counts: conspiracy to possess with intent to distribute narcotics resulting in death or serious bodily injury, possession with intent to distribute drugs, possession of a firearm in furtherance of drug trafficking, and conspiracy to possess a firearm in furtherance of drug trafficking. He was convicted on all counts by a jury. Before trial, he moved to suppress the Facebook evidence, arguing the search warrant was overbroad and lacked particularity, and requested a Franks hearing, alleging falsehoods in the warrant affidavit. The United States District Court for the Middle District of Pennsylvania denied these motions, admitted certain witness testimony, and imposed a mandatory life sentence under 21 U.S.C. § 841(b)(1)(C) based on his prior convictions and the resulting death. The United States Court of Appeals for the Third Circuit affirmed the convictions, holding that the good faith exception shielded the Facebook evidence from suppression, that the evidence was sufficient to support all convictions (including firearm possession via gun-for-drugs trades), and that the evidentiary rulings were not erroneous. However, the Court vacated the life sentence, holding that the District Court erred by not applying the traditional categorical approach to determine whether the prior state drug convictions qualified as “felony drug offenses” under federal law, and remanded for resentencing. View "USA v. Rosario" on Justia Law

USA v. Riddy

2026-07-01T09:00:12-08:00

DEA investigators received information indicating that an individual was distributing cocaine base with a co-defendant in Monroe County, Pennsylvania. The individual often requested payments from customers via Cash App and either conducted drug transactions personally or sent the co-defendant to do so. Cash App records showed approximately $180,000 in payments. Agents arranged controlled purchases, during which the co-defendant drove the individual's vehicle for several transactions. After executing a search warrant at the individual's residence, agents seized cocaine, paraphernalia, a drug ledger, financial records, and cash. The individual was later charged in a federal superseding indictment with several drug-related counts and pled guilty to conspiracy to distribute and possess with intent to distribute cocaine. The United States District Court for the Middle District of Pennsylvania reviewed the presentence report, which recommended a two-level leadership enhancement under U.S.S.G. § 3B1.1(c) for being a “manager” or “supervisor” of criminal activity. This enhancement resulted in a guideline range of 120 to 135 months, subject to a statutory minimum sentence of ten years. Without the enhancement, the individual would have been eligible for a sentence below the statutory minimum under the safety valve provision. The individual objected, but the District Court relied on Sentencing Guidelines commentary and applied the enhancement, sentencing him to 120 months’ imprisonment. The appeal challenged only the District Court’s application of the leadership enhancement. The United States Court of Appeals for the Third Circuit reviewed the District Court’s interpretation of the Sentencing Guidelines de novo and factual findings for clear error. The Third Circuit held that the District Court erred by deferring to the Guidelines’ commentary without first determining whether the Guideline text was genuinely ambiguous as required by circuit precedent. However, since the terms “manager” and “supervisor” were not genuinely ambiguous, and the factual findings supported the enhancement, the error was harmless. The Third Circuit affirmed the District Court’s judgment of sentence. View "USA v. Riddy" on Justia Law

USA v. Craddock

2026-07-01T09:00:12-08:00

After being arrested following a slow-speed pursuit in November 2020, the defendant was found with a disassembled Glock pistol and ammunition. The firearm contained two serial numbers: one was fully legible on the slide, while the other, located on the pistol frame, was partially visible but mainly scratched off, rendering several characters illegible. As a convicted felon, the defendant was charged with unlawful possession of a firearm and pleaded guilty. Prior to sentencing, the U.S. Probation Office recommended a four-level sentence enhancement under § 2K2.1(b)(4)(B)(i) of the U.S. Sentencing Guidelines, which applies if any firearm involved had a serial number modified to be illegible or unrecognizable to the unaided eye. At the sentencing hearing, the United States District Court for the Middle District of Pennsylvania found that certain characters of the serial number on the pistol frame were not legible, thus applying the four-level enhancement. The District Court ruled that the presence of a separate, legible serial number on the firearm’s slide was irrelevant to the enhancement’s application. The defendant appealed this decision. The United States Court of Appeals for the Third Circuit reviewed the District Court’s interpretation of the Guidelines de novo. The appellate court concluded that the plain language of § 2K2.1(b)(4)(B)(i) requires only that a firearm have at least one serial number rendered illegible or unrecognizable, regardless of whether another serial number on the same firearm remains legible. The court rejected the defendant’s argument that the enhancement should not apply if the firearm retains any complete, legible serial number. The Third Circuit affirmed the judgment of the District Court, holding that the enhancement applies so long as any serial number on the firearm has been modified to be illegible. View "USA v. Craddock" on Justia Law

USA v. Aumiller

2026-07-01T09:00:12-08:00

Between 2011 and 2017, the Internal Revenue Service sought to collect unpaid taxes from an individual and his business. The individual was indicted on two counts of tax evasion. The indictments alleged that, among other acts, he attempted to evade the collection of taxes by using a bank account that was not disclosed to the IRS, and specifically by submitting financial disclosure forms that omitted these accounts when disclosure was required. The case was first heard in the United States District Court for the Middle District of Pennsylvania. The defendant moved to dismiss the indictments, arguing that the government had not alleged or proven an affirmative act of evasion within the applicable six-year statute of limitations. The District Court denied these motions. At trial, the government presented evidence that the defendant had knowingly failed to disclose certain bank accounts on forms submitted to the IRS within the limitations period. After the government’s case, the defendant’s motion for judgment of acquittal was denied. The jury found him guilty on both counts. On appeal, the United States Court of Appeals for the Third Circuit reviewed the District Court’s denials. The Third Circuit held that intentionally filing forms with the IRS that omitted required disclosure of bank accounts constitutes an affirmative act of tax evasion under 26 U.S.C. § 7201. The court found that the indictments, together with the bill of particulars, sufficiently identified this conduct within the statute of limitations. It also held that there was sufficient evidence for a rational jury to find guilt beyond a reasonable doubt. The Third Circuit affirmed the judgment of the District Court. View "USA v. Aumiller" on Justia Law

USA v. Espanola

2026-07-01T07:30:46-08:00

A contractor for the City of Moline, Illinois, discovered in early 2021 that city payments totaling over $420,000 had been diverted to a fraudulent bank account at Washington Federal Bank. That account belonged to Luisito Espanola, who had opened it under the name GS International, LLC, which he controlled. Investigators found that Espanola quickly moved the stolen funds by depositing checks to a Citibank account, purchasing cryptocurrency, and sending money to other entities. Digital evidence, including WhatsApp messages between Espanola and a co-conspirator, detailed their planning and execution of the fraud. The United States District Court for the Central District of Illinois tried Espanola on two counts of wire fraud and two counts of money laundering. During discovery, Espanola produced a WhatsApp chat log as a defense exhibit; the government then moved to admit the chat log in its case-in-chief. The district court admitted the messages, relying on their distinctive characteristics and Espanola’s production of them under Rule 16(b)(1)(A). The jury convicted Espanola on all counts, and the district court sentenced him to 32 months in prison. On appeal, the United States Court of Appeals for the Seventh Circuit reviewed whether the district court’s reliance on Espanola’s production of the messages as a basis for authentication under Federal Rule of Evidence 901(b)(4) violated his right to testify. The court held that it did not, as the admission of government evidence does not infringe upon the defendant’s right to testify, which is implicated only by the exclusion of defense evidence. The Seventh Circuit further held that, regardless of circumstances of discovery, the WhatsApp messages were authenticated by their content and corroborating records. The court affirmed the district court’s judgment. View "USA v. Espanola" on Justia Law

State v. Ragin

2026-07-01T04:05:48-08:00

The defendant was convicted of murder and criminal possession of a pistol following the fatal shooting of a victim outside a bar in Bridgeport. The investigation relied in part on cell phone records obtained from the defendant’s service provider, which included call-identifying information and cell site location information (CSLI). The police acquired these records for a period spanning April 20 to May 8, 2017, but due to the provider's use of Coordinated Universal Time, the records also included four hours of data from the evening immediately preceding the murder. The prosecution used these records, combined with witness testimony, to place the defendant in the area of the shooting. Prior to trial in the Superior Court, the defendant moved to suppress the cell phone records, arguing that the search warrant lacked probable cause and particularity, was overbroad, and that the additional four hours of data were outside the warrant’s scope. The trial court denied the motion, finding probable cause and sufficient particularity, and determined that the service provider was not acting as a state agent when it voluntarily produced the extra data. At trial, the jury convicted the defendant of murder and criminal possession of a pistol, and the court acquitted him on two other firearm-related charges. The defendant appealed his conviction. The Supreme Court of Connecticut reviewed the case and affirmed the trial court’s denial of the motion to suppress. It held that the warrant was supported by probable cause and was sufficiently particular in time frame, even without specifying a time zone. The Court also concluded that suppression of the four extra hours of data was unwarranted because the police had probable cause for those records, and there was no evidence of improper police conduct. The exclusionary rule did not apply under these circumstances. The judgment of conviction was affirmed. View "State v. Ragin" on Justia Law

Hilton v. Commissioner of Correction

2026-07-01T04:05:47-08:00

The petitioner was convicted of murder and related offenses following the shooting death of a man in New Haven, Connecticut. The prosecution’s case rested on eyewitness testimony identifying the petitioner as the shooter, forensic evidence including blood matching the victim’s DNA found on the petitioner’s clothing, and the expert opinion of the associate medical examiner, who concluded the fatal wound was caused by the gun being pressed against the victim’s skin. Defense counsel did not present an expert to counter the state’s testimony regarding the wound. The petitioner later challenged his conviction in habeas proceedings, asserting ineffective assistance of both his trial and habeas counsel for failing to adequately challenge the state’s medical evidence. The Superior Court denied the petitioner’s first habeas petition, finding that counsel’s cross-examination and strategy regarding the medical examiner’s testimony were reasonable, and that the evidence presented did not contradict the state’s expert. On a second habeas petition, the petitioner introduced a new expert, who opined the wound could not have been a contact wound. The habeas court found this expert not credible, noting his failure to review prior relevant testimony and to account for other forensic details, and again denied relief. The Connecticut Appellate Court affirmed, holding that the habeas court applied the correct legal standard for evaluating expert credibility and distinguishing the case from Lapointe v. Commissioner of Correction, 316 Conn. 225 (2015). The Connecticut Supreme Court reviewed whether the Appellate Court was correct in concluding that the habeas court used the proper standard for assessing expert credibility. The Supreme Court held that Lapointe did not establish a new legal standard for such credibility determinations and reaffirmed that the Strickland v. Washington, 466 U.S. 668 (1984) standard governs ineffective assistance claims. The judgment of the Appellate Court was affirmed. View "Hilton v. Commissioner of Correction" on Justia Law

State v. Hagberg

2026-06-30T13:38:34-08:00

The defendant, a seventy-year-old man with a long history of alcohol use, was stopped by law enforcement after driving erratically and making multiple traffic violations. He was observed to be impaired, failed a field sobriety test, and later refused breath and blood tests, leading to a warrant for a blood draw that revealed a blood alcohol content over three times the legal limit. Investigation revealed he was driving with a suspended license and had three prior DUI convictions. He was charged with felony DUI (fourth or subsequent offense) and driving while suspended, but the latter charge was dismissed in exchange for his guilty plea to the DUI charge. The Montana Sixteenth Judicial District Court sentenced him to thirteen months with the Department of Corrections, recommended placement in an alcohol treatment program, and imposed a consecutive four-year suspended sentence. The court also imposed the statutory minimum fine of $5,000 but suspended half of it due to the defendant’s financial circumstances. The defendant appealed the imposition of the fine, arguing that the statute mandating the fine was unconstitutional based on recent case law. He maintained that the fine should not have been imposed without proper consideration of his ability to pay. The Supreme Court of the State of Montana held that the defendant did not waive his right to appellate review of the fine by agreeing to it in the plea agreement, as subsequent case law developments questioned the constitutionality of the statute. The Court reaffirmed that the sentencing court must impose the mandatory fine under the statute, then determine the defendant’s ability to pay, and may suspend any portion of the fine accordingly. The Supreme Court affirmed the imposition of the $5,000 fine but vacated the portion of the judgment relating to the fine and remanded to the District Court for explicit findings on the defendant’s ability to pay before determining how much of the fine should be suspended. View "State v. Hagberg" on Justia Law

State v. Jones

2026-06-30T13:35:03-08:00

Police responded to a domestic violence call involving the defendant after his girlfriend reported he had a firearm. Officers later found a purple handgun along the route the defendant had taken, and DNA evidence linked the gun to him. He was charged with felony domestic violence, misdemeanor unlawful carrying of a handgun, and felony unlawful carrying of a handgun by a felon with a prior conviction within the past fifteen years. The charging documents listed his two previous Texas felony convictions—one for Felon in Possession of a Weapon in 2014 and another for Aggravated Assault–Family Member in 2017—as the basis for the firearm charges. The Tippecanoe Superior Court dismissed both handgun-related charges, finding that the charging information was not sufficiently specific, did not constitute an offense, and that the statute used to enhance his charge was unconstitutionally vague under both federal and state constitutions. The trial court referenced an unrelated but identical dismissal for another defendant and issued a final judgment, allowing the State to appeal directly. The Indiana Supreme Court reviewed the case under its mandatory jurisdiction following a trial court finding of unconstitutionality. The court held that the charging information for both the misdemeanor and felony handgun counts was sufficiently certain and constituted an offense under Indiana law, as it included the necessary elements and identified the prior convictions. The court further held that the trial court had misapplied the relevant statute and that the enhancement to a felony did not require the prior out-of-state conviction to be substantially similar to an Indiana offense, only that it was a felony within fifteen years. The Indiana Supreme Court reversed the trial court’s dismissal of both handgun charges and remanded for further proceedings. View "State v. Jones" on Justia Law

State v. Gomez

2026-06-30T13:35:02-08:00

A man was arrested in Indiana after his wife reported to police that he had a handgun in his backpack and a prior felony conviction. The State charged him with three offenses: felony domestic battery (not at issue here), misdemeanor unlawful carrying of a handgun as a person with a prior felony conviction, and felony unlawful carrying of a handgun, alleging that he had a felony conviction within the last 15 years. The charging documents referenced his 2016 Illinois felony conviction for Aggravated Unlawful Use of a Weapon/Vehicle. The Tippecanoe Superior Court dismissed the two handgun charges. It found the information insufficiently certain because it did not specify the prior felony conviction’s statutory basis and concluded the charges did not constitute an offense. For the felony count, the court also held that Indiana’s reference statute, which allows consideration of out-of-state convictions, was unconstitutionally vague unless the out-of-state conviction was “substantially similar” to an Indiana crime. The trial court further speculated that the Indiana Supreme Court’s prior decision in State v. Hancock was wrongly decided and should be reconsidered. The Indiana Supreme Court reviewed the case on direct appeal. It held that the charging information, when read with the probable cause affidavit, provided sufficient notice to the defendant of the nature of the charges and the underlying Illinois felony conviction. The Court clarified that Indiana’s statute prohibits handgun possession by anyone convicted of a felony, regardless of whether the conviction occurred in Indiana or another jurisdiction, and does not require a “substantially similar” analysis for general felony references. The Supreme Court reversed the trial court’s dismissal of the handgun charges and remanded the case for further proceedings. View "State v. Gomez" on Justia Law

People v. Powell

2026-06-30T13:13:07-08:00

In this case, the defendant was convicted by a jury in 2008 of first degree murder and being a felon in possession of a firearm. The jury also found that he personally and intentionally discharged a firearm causing great bodily injury or death. In 2009, he was sentenced by the Superior Court of California, County of San Mateo, to a total term of 50 years to life, with a concurrent three-year term for the firearm possession charge. At sentencing, the court awarded him 1,076 days of presentence custody credit, with no conduct credit. This credit was reflected in the minute order and abstract of judgment. Following the conviction, the California Court of Appeal, First Appellate District, Division Four, affirmed the judgment in 2012, and the California Supreme Court later denied review. In 2023 and 2024, the defendant filed several motions in the trial court seeking correction of his presentence custody credits and a full resentencing, including the application of new, ameliorative laws enacted after his original sentencing. The trial court, after briefing and argument, corrected the custody credits to 1,078 days but rejected the request for a full resentencing or application of new statutory amendments. The trial court also amended the abstract of judgment to clarify the sentence on the firearm possession charge was concurrent. Upon appeal, the California Court of Appeal, First Appellate District, Division Four, held the trial court had inherent authority to correct clerical errors regarding the computation of presentence custody credits, and directed the credit be set at 1,079 days. The court further held that this correction did not entitle the defendant to a full resentencing, as the judgment remained final. The trial court’s order was affirmed as modified, and the court directed preparation of amended abstracts of judgment reflecting the corrected credits. View "People v. Powell" on Justia Law

State v. Tolentino

2026-06-30T11:03:47-08:00

After being stopped for speeding late at night, the defendant exited his vehicle and was ordered to the ground by a police officer, who drew his firearm. The defendant initially complied but then fled, leading to a physical confrontation in which he and the officer exchanged blows. After further pursuit and struggle, a second officer arrived, and all three individuals ended up on the ground. The defendant was handcuffed, and as he was lifted to his feet, he stated, “I’m sorry. I was just trying to get a Zip Pac.” The defendant was charged with assault against a law enforcement officer in the first degree, based on allegations that he caused bodily injury to the officer while the officer was performing his duties. Prior to trial in the Circuit Court of the First Circuit, the defendant moved in limine to exclude his statement, arguing it was involuntary. The prosecution conceded the defendant was in custody but denied that interrogation had occurred. The court denied the motion in limine, ruling the statement admissible as an “excited utterance” under Hawai‘i Rules of Evidence Rule 803(b)(2), and declined to hold an evidentiary voluntariness hearing. The prosecution asked the court to find the statement was not coerced, which it did, without an evidentiary hearing. The jury acquitted the defendant of the first-degree charge but convicted him of the lesser-included offense of assault against a law enforcement officer in the second degree. The defendant appealed, arguing error in the failure to hold a voluntariness hearing. The Intermediate Court of Appeals affirmed, holding that a voluntariness determination, rather than a hearing, was required. The Supreme Court of the State of Hawai‘i reviewed the case and held that article I, sections 5 and 10 of the Hawai‘i Constitution, and Hawai‘i Revised Statutes § 621-26, independently require a pretrial evidentiary hearing to establish voluntariness before a factfinder hears an inculpatory statement. Because no such hearing occurred, the conviction was vacated and the case remanded for a new trial. View "State v. Tolentino" on Justia Law

People v. DePape

2026-06-30T10:02:57-08:00

The case concerns a criminal prosecution arising from an incident in October 2022, when David Wayne DePape broke into the home of Paul Pelosi, husband of then Speaker of the United States House of Representatives, Nancy Pelosi. DePape entered the residence armed with a hammer and zip ties, confronted Paul Pelosi, and demanded to see Nancy Pelosi. After a series of threatening interactions, DePape ultimately struck Paul Pelosi in the head with a hammer, causing significant injuries. Police officers witnessed the attack and immediately subdued DePape, who was later found to have planned additional violent acts against other individuals. DePape was initially convicted in federal court for attempted kidnapping of a federal official and assault on an immediate family member of a federal official, both arising from the same incident. Following his federal conviction and sentencing, DePape faced separate charges in the Superior Court of San Francisco County, including attempted murder, elder abuse, and assault with a deadly weapon. After trial commenced, DePape moved to dismiss certain counts on double jeopardy grounds under California Penal Code section 656, arguing that his federal conviction barred further state prosecution for offenses based on the same physical acts. The trial court granted the motion to dismiss three counts—attempted murder, elder abuse, and assault with a deadly weapon—finding these were founded on the same act for which DePape had already been convicted federally. The Court of Appeal of the State of California, First Appellate District, Division Two, reviewed the trial court’s order. It affirmed the dismissal, holding that under section 656, California cannot prosecute offenses based on the same physical act for which a defendant has already been convicted in federal court, even if the state offenses require additional nonact elements such as intent or premeditation. The court concluded that only conduct, not mental state or other nonact elements, determines the application of statutory double jeopardy protections. View "People v. DePape" on Justia Law

STATE v. CULLINS

2026-06-30T09:04:22-08:00

Deanthony Cullins was indicted on multiple counts, including malice murder and aggravated assault, stemming from a June 2022 incident in which he was accused of shooting at a vehicle, resulting in the death of Dy’Sheae Hall. Cullins claimed self-defense. In the lead-up to trial, the State sought a continuance days before the scheduled date, citing late receipt of deposition transcripts, but the trial court denied the request. The State also filed an untimely motion to admit other acts evidence, which was denied. During trial, the prosecutor questioned a detective about Cullins’s refusal to make a statement to police, prompting the defense to object on grounds that the questioning improperly commented on Cullins’s right to remain silent. The defense moved for a mistrial, suggesting the prosecutor’s conduct was intentional to provoke a mistrial, and the trial court granted the mistrial. After the mistrial, Cullins filed a plea in bar, arguing that retrial should be barred under the Double Jeopardy Clause because the State had intentionally provoked the mistrial. The Superior Court of DeKalb County held a hearing and found that the prosecutor’s actions were deliberate, noting the State’s lack of readiness for trial, the benefit to the State of a second chance, and the seasoned experience of those involved. The trial court concluded that the State had goaded the defense into seeking a mistrial. On appeal, the Supreme Court of Georgia reviewed whether the trial court clearly erred in finding that the State had intentionally provoked a mistrial. The Supreme Court determined there was evidence to support the trial court’s findings and that they were not clearly erroneous. The Court affirmed the grant of the plea in bar, holding that retrial was barred because the prosecutor’s conduct was intended to provoke a mistrial for a more favorable opportunity to convict. View "STATE v. CULLINS" on Justia Law

SMITH v. STATE

2026-06-30T09:04:21-08:00

The case concerns the shooting death of Tobias Fleming outside an apartment complex in Richmond County, Georgia. Zaiara Dantrice Smith attended a family gathering at the apartment with several relatives, including Fleming and Tamika Smith. Witnesses testified that Smith, wearing a yellow shirt and jeans, arrived in a burgundy Kia Optima. Later, Smith and several men went outside; after some men left, gunshots were heard. Witnesses saw Smith running from the scene and leaving in the burgundy Kia. Investigators found the vehicle near the home of Smith’s sister-in-law and later recovered a Smith & Wesson 9mm handgun from the house where Smith had stayed. Forensic evidence linked the gun to the shell casings found at the scene. A Richmond County grand jury indicted Smith for malice murder, felony murder predicated on aggravated assault, and possession of a firearm during the commission of a felony. After a jury trial in the Superior Court of Richmond County, Smith was found guilty on all counts. He was sentenced to life without parole for malice murder and five years consecutively on the firearm charge. The court vacated the felony murder count by operation of law. Smith’s motion for a new trial was denied, and he appealed to the Supreme Court of Georgia. The Supreme Court of Georgia held that the evidence was sufficient to authorize a rational jury to find Smith guilty beyond a reasonable doubt under both constitutional due process and Georgia statutory law. The Court also held that the trial court did not abuse its discretion in admitting body camera footage showing a police officer attempting CPR on Fleming, finding its probative value outweighed any unfair prejudice. The judgment was affirmed. View "SMITH v. STATE" on Justia Law

MOSLEY v. STATE

2026-06-30T09:04:20-08:00

An inmate at Georgia State Prison was indicted for malice murder, felony murder, aggravated assault, and possession of prohibited items, following the stabbing death of another inmate. Evidence showed the defendant refused to allow guards to enter the cell after the incident, and the victim was found dead from multiple stab wounds. Homemade knives bearing the victim’s blood were discovered near the cell. The defendant claimed self-defense, citing the victim’s drug use, paranoia, and prior murder conviction, and testified he feared for his life during the altercation. A jury trial held in the Superior Court of Tattnall County resulted in convictions for felony murder and possession of prohibited items; malice murder was not sustained. The trial court initially granted a motion for new trial due to delays in preparing the transcript, but later rescinded this order after the transcript was completed. Following an amended motion for new trial and an evidentiary hearing, the court denied the motion. The defendant appealed the convictions and the denial of a new trial. The Supreme Court of Georgia reviewed the case and affirmed the judgment. The Court held that the evidence was sufficient under Jackson v. Virginia to support the convictions, and the defendant failed to demonstrate ineffective assistance of counsel regarding venue. The trial court’s reconsideration of its order granting a new trial was proper within the same term. The jury instructions challenged by the defendant did not constitute plain error. Any error in admitting prior bad acts evidence was harmless given the strength of the State’s case and limiting instructions. The defendant was allowed to testify about the victim’s prior murder conviction. Alleged prosecutorial misconduct and procedural irregularities did not warrant reversal, and the delay in preparing the transcript did not result in actual prejudice. View "MOSLEY v. STATE" on Justia Law

OWENS v. STATE

2026-06-30T09:04:20-08:00

The case concerns the conviction of an individual who, along with her partner, was responsible for the care of three minor children, including the eight-year-old victim who died in November 2021. The family lived in an extended stay hotel at the time. After reporting the child missing, inconsistencies in the stories told by the defendant and her partner raised suspicion. Investigators found no evidence that the child left the hotel room as claimed by the adults. Physical evidence of abuse was observed on the surviving children, and videos recovered from the defendant’s cell phone showed her and her partner abusing the children. The defendant was also linked to actions taken to conceal the child’s death, including suspicious purchases, travel logs, and digital evidence. The deceased child’s body displayed evidence of severe and prolonged abuse, malnutrition, and was found wrapped in trash bags at a dumpsite. The Superior Court of Chatham County tried the case, and the jury found the defendant guilty of malice murder, multiple counts of cruelty to children, concealing the death of another, and making false statements. The court sentenced her to life in prison without parole for malice murder and imposed consecutive sentences for the other offenses. Predicate felonies were merged or vacated as required by law. After her conviction, the defendant filed a motion for a new trial, which was denied. Upon appeal, the Supreme Court of Georgia reviewed whether the evidence was constitutionally sufficient to support the convictions for malice murder and child cruelty. The court held that, when viewed in the light most favorable to the verdict, the evidence was sufficient for a rational jury to find the defendant guilty beyond a reasonable doubt, either as the direct perpetrator or as a party to the crimes. The Supreme Court of Georgia affirmed the convictions. View "OWENS v. STATE" on Justia Law

BROWN v. STATE

2026-06-30T09:04:20-08:00

Three individuals were hired to install flooring in an Augusta apartment: Dewey Brown, Roosevelt Williams, and Hurie Franklin. On August 20, 2018, after returning from lunch, Brown suddenly attacked Williams while Williams was preparing to resume work. Franklin, at Williams’s request, left to get help, and upon return with authorities, found Brown on top of Williams with his arm around Williams’s neck. Williams was pronounced dead at the scene, with autopsy evidence showing death by manual strangulation. Brown suffered non-life-threatening injuries and did not testify at trial. The Superior Court of Richmond County indicted Brown for malice murder and felony murder. At trial in March 2019, a jury convicted Brown on both counts. The court sentenced him to life imprisonment without parole for malice murder and vacated the felony murder count by operation of law. Brown's motion for new trial was denied after an evidentiary hearing in March 2023. He filed a timely notice of appeal, which was amended and submitted for review. The Supreme Court of Georgia reviewed Brown’s appeal. The Court held that the evidence was constitutionally sufficient to support the malice murder conviction, applying the standard from Jackson v. Virginia. The trial court did not err in refusing to instruct the jury on accident or involuntary manslaughter, as there was not even slight evidence to support these theories. The exclusion of evidence regarding Franklin’s probation status was, if error, harmless. Brown’s claims of ineffective assistance of counsel were rejected, as he failed to show deficient performance or resulting prejudice under Strickland v. Washington. The Supreme Court of Georgia affirmed the conviction and all rulings by the lower court. View "BROWN v. STATE" on Justia Law

STATE v. OVALLE

2026-06-30T09:04:19-08:00

A 16-year-old named Nicholson died after ingesting fentanyl in June 2021. Evidence showed that Nicholson obtained fentanyl from Ovalle, who admitted in a police interview to selling drugs to Nicholson at a restaurant where Nicholson worked. Surveillance footage and text messages corroborated the drug transaction. After Nicholson returned from meeting Ovalle, his coworkers observed significant changes in his behavior, and he later died at home. Toxicology reports confirmed fentanyl as the sole cause of death, with no heroin detected. A Bartow County grand jury indicted Ovalle for felony murder, predicated on the distribution of fentanyl, and for violating the Georgia Controlled Substances Act. After a jury trial in the Superior Court of Bartow County, Ovalle was found guilty on both counts. The trial court sentenced Ovalle to life in prison for felony murder and merged the drug violation for sentencing. Ovalle, through counsel, filed motions for a new trial. The trial court granted Ovalle a new trial on the felony murder count, finding the evidence insufficient to satisfy the “in the commission of” element, reasoning that Nicholson’s fatal ingestion of fentanyl occurred after the drug distribution was completed, and declined to address other arguments about proximate cause. The Supreme Court of Georgia reviewed the State’s appeal of the trial court’s order granting a new trial. The Court determined that the trial court applied the wrong legal standard in assessing the “in the commission of” requirement for felony murder by focusing only on the victim’s conduct rather than the defendant’s. As a result, the Supreme Court of Georgia vacated the trial court’s judgment and remanded the case for further proceedings consistent with its opinion. View "STATE v. OVALLE" on Justia Law

COLLINS v. STATE

2026-06-30T09:04:18-08:00

The case involves two defendants who were convicted of felony murder and related crimes following the shooting death of a man at a gas station. Surveillance footage revealed that the defendants, along with a third accomplice, arrived in a rented Mercedes, attempted to take the victim’s vehicle, and ultimately shot him during a struggle. Investigators linked the defendants to the scene through cell phone records, rental car information, DNA evidence, and text messages sent shortly after the crime. Expert testimony established that the defendants were members of a criminal street gang, and evidence of prior criminal activity was admitted. After an initial trial ended in a mistrial due to prosecutorial misconduct, a second trial in the Superior Court of Gwinnett County resulted in guilty verdicts for all counts against the defendants. The trial court sentenced them to life imprisonment without parole for felony murder and consecutive sentences for other charges. Defendants filed motions for new trial, which were denied, and then appealed their convictions. The Supreme Court of Georgia reviewed the appeals. It held that the evidence was constitutionally sufficient to support the convictions for hijacking and related gang offenses, both as principals and as parties to the crime. The Court found that the trial court’s omission of an accomplice corroboration instruction was affirmatively waived. It rejected claims of error under Bruton v. United States, finding no admissible statement incriminating the appellants. The Court determined that the aggravated assault jury instruction, even if imprecise, did not likely affect the outcome. The rule of lenity was found inapplicable to sentencing under the hijacking statute. Claims regarding ineffective assistance of counsel and errors in administering the juror oath were also rejected. The Supreme Court of Georgia affirmed the convictions and sentences. View "COLLINS v. STATE" on Justia Law

STATE v. POSTELL

2026-06-30T09:04:18-08:00

On March 30, 2020, a man shot and killed his nephew outside their family’s neighboring homes following a verbal altercation that escalated. The nephew, who had recently moved into the shooter’s home after being banned from his mother’s house for bringing guns there, was found dead in a field with a handgun nearby. The shooter, who was not at the scene when police arrived, was later arrested and gave conflicting accounts in two custodial interviews, eventually claiming self-defense based on his fear of the nephew, who, he asserted, had a reputation for violence and prior acts of aggression. The only eyewitness testimony regarding the events leading up to the shooting came from the nephew’s sister. A jury in the Superior Court of Bulloch County convicted the shooter of malice murder and other offenses. However, the trial court granted the defendant’s motion for a new trial, finding that evidence of the nephew’s violent character and prior specific acts—known to the defendant—was wrongly excluded from trial. These excluded pieces included redacted portions of the defendant’s custodial statements and his own testimony about the nephew’s reputation and acts, as well as unspecified testimony from family members. The State appealed this ruling. The Supreme Court of Georgia reviewed the trial court’s grant of a new trial de novo. The Court held that evidence of the victim’s violent character (in the form of reputation or opinion testimony) and of specific prior acts, if known to the defendant and relevant to his claim of self-defense, should have been admitted. The exclusion of such evidence was an abuse of discretion, and the trial court properly granted a new trial under OCGA § 5-5-22. The judgment granting a new trial was affirmed. View "STATE v. POSTELL" on Justia Law

BELL v. STATE

2026-06-30T09:04:18-08:00

Two defendants were tried jointly for their roles in the shooting death of an individual at a gas station. On the day of the incident, the defendants and the victim were together with others when an attempted armed robbery occurred. During the confrontation, one defendant brandished a firearm and attempted to rob the other. This escalated into a shootout involving both defendants, during which the victim, who was unarmed, was shot multiple times and died from his injuries. The events were witnessed by bystanders, captured on surveillance footage, and supported by physical evidence at the scene. The Superior Court of Fulton County conducted the trial, where one defendant was convicted of malice murder and related offenses, while the other was convicted of felony murder and associated crimes. Both defendants filed motions for new trial, which were denied after hearings. Each defendant then filed timely appeals. On review, the Supreme Court of Georgia considered several challenges. Both defendants argued that the evidence was insufficient to support their respective murder convictions. The court held that the evidence, when viewed in the light most favorable to the verdicts, was sufficient for a rational jury to find both defendants guilty beyond a reasonable doubt. The court further found that the evidence supported the rejection of a self-defense claim and that the actions leading to the victim’s death were a reasonably foreseeable result of the attempted armed robbery, satisfying the proximate cause and “in the commission of” requirements for felony murder. The court also determined that claims of prosecutorial misconduct and ineffective assistance of counsel were either procedurally barred or without merit. Accordingly, the Supreme Court of Georgia affirmed the convictions and judgments. View "BELL v. STATE" on Justia Law

RUCKER v. STATE

2026-06-30T09:04:17-08:00

Three men were indicted for the robbery and murder of an apartment resident, with additional charges including home invasion, armed robbery, aggravated assault, burglary, cruelty to children, and illegal firearm possession. The incident occurred when the three defendants forced entry into the victim’s apartment, threatened him with a gun, stole drugs and money, and ultimately shot him multiple times, resulting in his death. Several eyewitnesses, including the victim’s roommates and visitors, identified two of the defendants as participants and as the shooter. Two young children were present in the apartment during the armed assault and shooting. The Superior Court of Fulton County conducted a joint jury trial for the three defendants. The jury convicted two of the defendants of all major charges except aggravated assault on one witness and one count of firearm possession, which was dismissed. The third defendant was convicted of most counts, but acquitted of malice murder and one aggravated assault. Each defendant received lengthy prison sentences, including life imprisonment for murder. Motions for new trial were filed and ultimately denied after extended post-trial proceedings. The defendants then appealed their convictions. The Supreme Court of Georgia reviewed the case. It held that the evidence was sufficient to support all convictions against both appellants, including the cruelty to children charges. The Court found that any error in admitting certain hearsay statements was either harmless or did not affect the outcome, and that the trial court did not abuse its discretion in admitting jail call recordings under the co-conspirator exception to hearsay. The Court also determined that the denial of motions to sever was not an abuse of discretion, as no clear prejudice was shown. The Supreme Court of Georgia affirmed all convictions and sentences. View "RUCKER v. STATE" on Justia Law

WARNER v. ESPITIA

2026-06-30T09:04:17-08:00

A former spouse filed a petition for contempt in Cobb County Superior Court, alleging that his ex-wife was behind on child support payments. He also submitted notices to the Georgia Department of Human Services claiming arrears. At a hearing, he admitted uncertainty about the arrears, attributing his calculations to his fiancée. The Cobb County court found his contempt petition frivolous, awarded attorney fees to the ex-wife, and determined the filings were intended to harass and intimidate her. Using this order, the ex-wife then filed a complaint in Paulding County Superior Court against her former spouse and his fiancée, alleging they conspired to file false documents and committed violations under the Georgia RICO Act and other statutes. The Paulding County Superior Court granted the defendants’ motion to dismiss, finding that there was no evidence they knowingly and willfully filed false documents, as required for the predicate acts under the RICO claim. The trial court concluded that the defendants believed their filings were accurate, and therefore, the RICO action failed. The court also stated that the RICO Act was not intended for civil matters of this nature. The ex-wife appealed, and the Court of Appeals affirmed, holding that it would be unreasonable to extend the Georgia RICO Act to “garden-variety domestic disputes.” The Supreme Court of Georgia reviewed the case and found that the Georgia RICO Act does not categorically exclude racketeering activity arising from domestic disputes. The Court held that the Act’s plain language applies broadly to “any person” who commits enumerated crimes, regardless of context, and the Act should not be limited by judicial interpretation to exclude domestic disputes. The Court vacated the Court of Appeals’ opinion and remanded the case for further consideration of the remaining arguments regarding the dismissal. View "WARNER v. ESPITIA" on Justia Law

WALKER v. STATE

2026-06-30T09:04:16-08:00

Walker was convicted of aggravated stalking following an incident in which he allegedly contacted Brittany Walker at a specific address in violation of a temporary protective order. The indictment for aggravated stalking charged that Walker contacted the victim at or about 3419 Pleasant View Court, Loganville, without her consent and for the purpose of harassment and intimidation. However, the indictment did not specify whether this location was the defendant’s residence or allege facts negating that possibility. After the verdict, Walker filed a timely motion in arrest of judgment, arguing that the aggravated stalking count of the indictment was substantively defective because it failed to allege all essential elements of the crime, specifically omitting the statutory requirement that the contact occur at a “place or places” other than the defendant’s residence. The trial court granted Walker’s motion, holding that the indictment was void for failing to allege this essential element. The Court of Appeals of Georgia reversed, reasoning that the indictment sufficiently stated the offense in the terms and language of the statute, and that the “other than the residence of the defendant” language was an affirmative defense rather than an essential element needing to be alleged. The Supreme Court of Georgia reviewed the case on certiorari. It held that the statutory requirement of “place or places,” including its statutory definition as “any public or private property occupied by the victim other than the residence of the defendant,” is an essential element of aggravated stalking under OCGA § 16-5-91. Because the indictment neither recited this statutory language nor alleged facts necessary to establish this element, the Supreme Court concluded the indictment was void. The Court reversed the judgment of the Court of Appeals, reinstating the trial court’s grant of the motion in arrest of judgment. View "WALKER v. STATE" on Justia Law

USA v. Williams

2026-06-30T09:00:12-08:00

The defendant was arrested after sexually abusing a 13-year-old girl and making and possessing child pornography, having coerced multiple minors into sending him explicit images and meeting him for sex. Law enforcement officers posed as one of the victims to apprehend him, and a grand jury indicted him on five federal charges, including traveling interstate to have sex with a minor, sexual exploitation of a child, coercion and enticement of a minor, and possession of child pornography. Following his arrest, the defendant repeatedly delayed proceedings, changed his mind about legal representation, and ultimately chose to represent himself at trial after several Faretta hearings, during which the District Court misinformed him about the maximum penalty on one count. The U.S. District Court for the District of New Jersey, after thorough Peppers colloquies, allowed the defendant to proceed pro se with standby counsel, despite the sentencing misinformation. During trial, the defendant behaved disruptively and withdrew his pro se status for closing arguments. The jury convicted him on all counts. Before sentencing, the government revealed the sentencing error, and the defendant moved for a new trial, claiming his waivers of counsel were neither knowing nor voluntary, and challenging the admission of certain evidence. The District Court denied the motion, finding the waivers valid based on the overall record, and sentenced him to life imprisonment. The United States Court of Appeals for the Third Circuit reviewed the appeal and affirmed the conviction and sentence. The court held that the defendant’s waivers of his right to counsel were both knowing and voluntary, even in light of the District Court’s error, because he was aware he faced a functional life sentence. It clarified that in cases where a defendant seeks to represent himself for improper purposes, courts may review the entire record to verify waiver validity. The court also rejected the evidentiary challenges to chat messages and evidence of other crimes. View "USA v. Williams" on Justia Law

United States v. Lynn

2026-06-30T08:32:44-08:00

The defendant was involved in a shooting at a homeless encampment in Tulsa, Oklahoma, resulting in the death of one individual and serious injury to another. The incident followed a dispute regarding stolen property, with witnesses testifying that the defendant fired shots into tents after a confrontation. The police recovered shell casings and matched them to a firearm later found in the possession of another individual, which was confirmed to belong to the defendant. Witness testimony indicated the defendant claimed he was shot at first, but no firearm was found at the scene associated with the victims. The United States District Court for the Northern District of Oklahoma presided over the trial, where a jury convicted the defendant of first-degree murder, assault with a dangerous weapon, assault resulting in serious bodily injury, and carrying and discharging a firearm during a crime of violence. The defendant was sentenced to life imprisonment plus ten years. On appeal, the defendant challenged the admission of a tribal database screenshot to prove Indian status, the inclusion of certain language in the self-defense instruction, and the court’s refusal to instruct the jury that the government must disprove imperfect self-defense beyond a reasonable doubt. The United States Court of Appeals for the Tenth Circuit reviewed the case. The court affirmed the district court’s admission of the tribal database record and its self-defense instruction, finding no abuse of discretion or legal error. However, it held that the district court erred by failing to instruct the jury that the government must disprove imperfect self-defense beyond a reasonable doubt, violating due process. The court remanded with instructions to vacate the murder conviction (Count One) and ordered further proceedings, while affirming the remaining convictions. View "United States v. Lynn" on Justia Law

United States v. Pineda

2026-06-30T07:01:12-08:00

Law enforcement arranged three controlled purchases of methamphetamine from Saul Pineda at his residence in Shakopee, Minnesota, between September and October 2022. Each transaction involved Pineda and a confidential informant. Following these buys, a search of Pineda’s property uncovered drug paraphernalia, a methamphetamine conversion lab, and approximately 31 pounds of methamphetamine buried in the yard. Pineda was indicted on multiple counts related to possession and distribution of methamphetamine. At trial, Pineda testified that he engaged in the drug sales because he was acting under threats to his life and the lives of his family members, originating from an alleged kidnapping and coercion by armed men in Mexico who later directed his actions in Minnesota. The United States District Court for the District of Minnesota heard the case. After Pineda’s testimony, the court considered whether to instruct the jury on the defense of duress. The district court declined to provide the instruction, finding that Pineda’s evidence did not establish an immediate, specific threat related to the charged offenses or the absence of reasonable legal alternatives, such as contacting law enforcement during the periods he was unmonitored. The jury subsequently found Pineda guilty on all counts. On appeal, the United States Court of Appeals for the Eighth Circuit reviewed whether the district court erred by not instructing the jury on duress. Applying de novo review to the sufficiency of the evidence for an affirmative defense, the appellate court held that Pineda’s evidence did not meet the requirements for a duress instruction, as the threats were not immediate or connected to the charged conduct and reasonable legal alternatives existed. The Eighth Circuit affirmed the district court’s refusal to instruct on duress and upheld Pineda’s convictions. View "United States v. Pineda" on Justia Law

United States v. Crump

2026-06-30T07:01:12-08:00

The case involved an individual who served as general manager at a Minnesota-based telemarketing company engaged in a nationwide scheme to defraud individuals by misrepresenting magazine subscription renewals. The operation used deceptive scripts to induce customers to purchase new subscriptions under the guise of reducing costs or renewing existing ones. The defendant was responsible for overseeing day-to-day operations, managing lead lists, and coordinating with other telemarketing entities. Evidence included email exchanges, consumer complaints, and state investigations indicating awareness and active participation in the fraudulent scheme. Previously, the United States District Court for the District of Minnesota heard the case. The defendant was charged with conspiracy to commit mail fraud and wire fraud, among others, and challenged the sufficiency of evidence, jury instructions, and alleged discovery violations. The district court denied the defendant’s motions for acquittal and a new trial, finding sufficient evidence of participation in the fraud, rejecting arguments about script truthfulness, and concluding that any government discovery failures did not prejudice the defense. The United States Court of Appeals for the Eighth Circuit reviewed the conviction. The court applied de novo review to sufficiency of evidence claims and found that a rational jury could have convicted the defendant based on the evidence presented. The court held the district court’s jury instructions were consistent with precedent regarding materiality in fraud cases and found no abuse of discretion. Regarding discovery, the Eighth Circuit determined there was no violation of Rule 16 or Brady concerning emails, as they were not in the government’s possession or control and the defendant could have accessed them independently. The court also agreed that the undisclosed digital evidence was not material under Brady. The Eighth Circuit affirmed the judgment of the district court. View "United States v. Crump" on Justia Law

People v. Ceus

2026-06-30T06:32:57-08:00

A group led by Madani Ceus, who asserted herself as a divine figure, lived communally and traveled across the United States before settling on a remote farm in Colorado. During their stay, Ceus declared two young girls, M.R. and H.M., to be spiritually tainted and exiled them to a car on the property in the heat of summer, forbidding any group member from providing them with food or water. The girls died after weeks of isolation, and their bodies were found in a severely decomposed state. Ceus, along with other adult members of the group, was arrested and charged with multiple offenses, including child abuse resulting in death. Following a jury trial in the District Court, Ceus was convicted of two counts of child abuse resulting in death, based on the jury's verdicts on the lesser included offenses of the original murder charges. The trial court rejected Ceus’s requests for specialized jury instructions and interrogatories that would have required the jury to make explicit findings on whether the abuse resulted in the girls’ deaths. The Colorado Court of Appeals determined that the trial court erred by not requiring the jury to make distinct findings on the result element (death) and held the error was not constitutionally harmless, remanding for the prosecution to elect between retrial or misdemeanor convictions. The Supreme Court of Colorado reviewed the case and agreed that the trial court erred in failing to require specific jury findings on whether the child abuse resulted in death. However, the court held that the error was constitutionally harmless because (1) the fact that the abuse resulted in the girls’ deaths was not meaningfully disputed at trial, (2) the jury instructions and verdict forms made clear the charges required child abuse resulting in death, and (3) the evidence connecting the abuse to the deaths was overwhelming. The court also found the evidence sufficient to sustain the convictions and reversed the judgment of the Court of Appeals, remanding for consideration of Ceus’s remaining claims. View "People v. Ceus" on Justia Law

USA v. Banks

2026-06-30T06:31:05-08:00

A man was stopped by police late at night after an officer observed him allegedly fail to signal 100 feet before making a left turn, as required by Illinois law. After he parked in a strip mall lot, officers initiated a traffic stop and asked for his license and proof of insurance. The driver’s insurance card was expired, prompting him to exit the car to call someone for updated proof. While the stop was ongoing, another officer arrived with a drug-sniffing dog, which alerted to narcotics outside the vehicle. Police then searched the car and found a handgun hidden in the center console, but no drugs. The driver was arrested and charged with being a felon in possession of a firearm. The United States District Court for the Central District of Illinois denied the defendant’s motion to suppress the handgun, finding the officer’s testimony credible enough to establish reasonable suspicion for the traffic stop and that the stop was not impermissibly prolonged. It also found the dog’s alert provided probable cause to search the vehicle. At trial, the court denied the defendant’s motion for a directed verdict, ruling there was sufficient evidence for the jury to convict him. The defendant’s post-trial motion for a new trial was also denied. The United States Court of Appeals for the Seventh Circuit reviewed the case and affirmed the district court’s rulings. The appellate court held that the district court did not clearly err in crediting the officer’s testimony about the traffic violation, that the duration of the stop was not unreasonably extended, and that the dog’s alert provided probable cause for the search. The court also found that there was sufficient evidence to support the conviction for knowing possession of a firearm by a felon. The judgment was affirmed. View "USA v. Banks" on Justia Law

USA v. Arrieta

2026-06-29T15:30:30-08:00

Six detainees at an Immigration & Customs Enforcement facility in El Paso, including the defendant, used improvised ropes to climb onto an unrailed roof two stories above the ground. For over three and a half hours, they refused commands to come down, demanded release and media attention, and threatened to jump if approached. The standoff required two specialized law-enforcement teams, and ended only after sublethal munitions were deployed. The facility then imposed a six-hour lockdown, suspending all activities, denying access to attorneys and families, and disrupting meal services. A grand jury charged the defendant and others with mutiny under 18 U.S.C. § 1792. The defendant pleaded guilty. During sentencing in the United States District Court for the Western District of Texas, the presentence report recommended the highest base offense level under U.S.S.G. § 2P1.3, arguing the conduct created a substantial risk of death or serious bodily injury. The defendant objected, advocating for the lowest base offense level, or alternatively, the middle tier for major disruption. The district court found the offense involved a major disruption to the institution’s operation, applied the middle tier (base offense level 16), and sentenced the defendant accordingly. The United States Court of Appeals for the Fifth Circuit reviewed whether the district court’s finding of “major disruption” was clearly erroneous. Applying the ordinary meaning of “major disruption,” the court concluded that the prolonged rooftop standoff, involvement of specialized teams, use of sublethal munitions, and subsequent facility-wide lockdown constituted a significant interruption to operations. The Fifth Circuit held that the district court’s finding was plausible in light of the record and not clearly erroneous, and therefore affirmed the district court’s sentence. View "USA v. Arrieta" on Justia Law

Monroe v. State of Indiana

2026-06-29T13:35:07-08:00

The defendant was charged with three offenses: murder, felony murder (murder during a robbery), and robbery resulting in serious bodily injury. She pleaded guilty to all counts without any plea agreement. Both parties agreed that the murder and felony murder counts should be “merged” due to double jeopardy concerns, meaning a conviction would be entered only for murder. At sentencing, the prosecution agreed the felony murder conviction should be vacated, but the defendant argued the robbery conviction should also be vacated on double jeopardy grounds. The trial court ultimately entered convictions for murder and robbery, but not for felony murder. On appeal, the Indiana Court of Appeals affirmed the trial court’s judgment. The appellate court relied on longstanding Indiana precedent that defendants who plead guilty cannot challenge the validity of their convictions on direct appeal, including on double jeopardy grounds. The court indicated that the defendant could seek post-conviction relief, but a direct appeal was not permitted. The Indiana Supreme Court reviewed the case. It reaffirmed the rule that a defendant who pleads guilty may not challenge their conviction through a direct appeal, even for double jeopardy claims. The Court clarified that defendants in this situation must first file a motion to withdraw their guilty plea as to the lesser included offense and request vacatur of that conviction. If the trial court denies the motion, the defendant may then directly appeal that denial. In this case, because the defendant did not file such a motion, the Supreme Court held that the robbery conviction could not be challenged on direct appeal and affirmed the lower court’s disposition regarding the sentence. View "Monroe v. State of Indiana" on Justia Law

P. v. Brown

2026-06-29T11:32:46-08:00

The defendant was convicted by a jury of first degree robbery, with a finding that the crime involved the taking of property valued at over $4,000. He was 36 years old at the time of the offense and had prior serious felony and strike convictions, though the trial court later struck those enhancements, leaving only the robbery conviction. The probation report noted his experience of childhood trauma as a mitigating factor, based on his mother’s early death and absence of a relationship with his father, though the defendant initially described his childhood as positive. The probation officer recommended the middle term for sentencing. The Superior Court of Riverside County reviewed the circumstances, including the aggravating factor regarding the amount taken and the mitigating factor of childhood trauma. The court determined that there was insufficient evidence to show that the defendant’s childhood trauma was a contributing factor in the commission of the robbery. As a result, the trial court imposed the upper term of six years, declining to apply the statutory presumption for a lower term under Penal Code section 1170, subdivision (b)(6)(A). On appeal, the California Court of Appeal, Fourth Appellate District, Division Two, considered whether the trial court abused its discretion by not applying the lower term presumption. The appellate court clarified that the presumption applies only when there is a causal connection between the defendant’s trauma and the offense. The court found substantial evidence supported the trial court’s finding that no such connection was established in this case and concluded that the lower term presumption did not apply. The judgment of the trial court was affirmed. View "P. v. Brown" on Justia Law

STATE OF LOUISIANA VS. DUNCAN

2026-06-29T08:36:37-08:00

The defendant was convicted in 1998 of first degree murder and sentenced to death after the drowning death of a 23-month-old child in his care. The prosecution’s case rested on forensic evidence suggesting the child was violently assaulted, bitten, sexually abused, and forcibly drowned, while the defense argued for accidental drowning due to a seizure and challenged the forensic findings. The conviction was affirmed on direct appeal, and certiorari was denied. Following conviction, the defendant pursued post-conviction relief in Louisiana’s Fourth Judicial District Court, presenting new evidence that undermined the reliability of the forensic experts whose testimony was pivotal at trial. This included developments in bite mark analysis and pediatric pathology, expert opinions that the death was accidental, and evidence impeaching a jailhouse informant’s confession testimony. The trial court held a multi-day evidentiary hearing and found the new evidence, especially regarding the state’s forensic experts, was reliable, noncumulative, and would likely have led to acquittal. Relief was granted under La. C.Cr.P. art. 930.3(1) (ineffective assistance) and art. 930.3(8) (factual innocence), and the conviction and sentence were vacated. The Supreme Court of Louisiana reviewed the trial court’s ruling for abuse of discretion, as the state did not contest legal errors in the factual innocence analysis. Applying La. C.Cr.P. art. 926.2, the court held that the defendant had presented new, reliable, noncumulative evidence which, viewed with all relevant evidence, proved by clear and convincing evidence that no rational juror would have found guilt beyond a reasonable doubt. The judgment vacating the conviction and sentence was affirmed, and relief was granted under La. C.Cr.P. art. 930.3(8). View "STATE OF LOUISIANA VS. DUNCAN" on Justia Law

STATE OF LOUISIANA VS. STEWART

2026-06-29T08:36:36-08:00

Curtis Lee Stewart, Jr. was indicted for second degree murder following the April 25, 2021 fatal shooting of Devonta Ennis in Baton Rouge, Louisiana. Surveillance video showed two vehicles, a white Chevrolet Traverse and a silver Nissan Armada, boxing in Mr. Ennis’s car before an occupant of the Traverse opened fire. Both vehicles were later found burned nearby; each was registered or leased to women romantically linked to Stewart. Cell phone records showed Stewart’s phone moving between the locations of the vehicle theft and the murder scene at relevant times. Testimony and recorded interviews indicated Stewart took one of the vehicles and later instructed witnesses not to cooperate with authorities. After a bench trial in the Nineteenth Judicial District Court, Stewart was found guilty and sentenced to life imprisonment without parole. The trial court’s per curiam noted that circumstantial evidence excluded every reasonable hypothesis of innocence. Stewart appealed. The Louisiana Court of Appeal, First Circuit, reversed the conviction, determining that the evidence failed to establish Stewart’s identity as the shooter and that the trial court’s conclusion was based on speculation. The appellate court emphasized the absence of physical evidence or witness identification directly linking Stewart to the shooting and found the State had not negated the possibility of misidentification. The Supreme Court of Louisiana reviewed the case, applying the Jackson v. Virginia standard, which requires the evidence to be viewed in the light most favorable to the prosecution. The Court found that the evidence, including Stewart’s involvement with the vehicles, his cell phone activity, witness tampering, and specific intent inferred from the circumstances, was sufficient for a rational trier of fact to convict Stewart as a principal to second degree murder, even absent direct evidence he fired the fatal shots. Accordingly, the Supreme Court of Louisiana reversed the appellate court’s judgment and reinstated Stewart’s conviction and sentence. View "STATE OF LOUISIANA VS. STEWART" on Justia Law

STATE OF LOUISIANA VS. OWNEY

2026-06-29T08:36:36-08:00

A juvenile in Orleans Parish was arrested and evidence was seized pursuant to warrants issued by a juvenile court hearing officer, rather than a judge or magistrate. The authority for the hearing officer to issue arrest and search warrants stemmed from local court rules adopted by the Orleans Parish Juvenile Court. The defendant challenged the validity of both the arrest and the search, arguing that the local rules conflicted with Louisiana statutes and the state constitution, which reserve warrant-issuing authority to judges and magistrates unless otherwise expressly permitted by law. The Criminal District Court for the Parish of Orleans denied the defendant’s motion to suppress the evidence obtained through the search and arrest warrants. The court held that the hearing officer acted with apparent authority under the court’s local rules, and that the warrants were valid at the time they were issued. Upon review, the Supreme Court of Louisiana addressed whether the local rules authorizing hearing officers to issue arrest and search warrants were valid under Louisiana law, and whether warrants already issued under those rules should be invalidated. The court held that the relevant provisions of the local rules conflicted with the Louisiana Children’s Code, the Louisiana Code of Criminal Procedure, and the Louisiana Constitution, and were therefore null and void. However, applying the de facto officer doctrine, the court found that the hearing officer’s acts were valid because the officer acted under color of authority before the rules were judicially declared invalid. Accordingly, the Supreme Court of Louisiana affirmed the trial court’s denial of the motion to suppress and remanded the case for further proceedings. View "STATE OF LOUISIANA VS. OWNEY" on Justia Law

CANNON V. USA

2026-06-29T08:01:23-08:00

The case centers on an FBI investigation into Lionel Cannon for federal drug trafficking. During a lawful search, agents seized $585,000 in cash from Cannon’s bedroom safe. However, FBI Special Agent Scott Bowman stole $218,200 of that cash before it was officially inventoried. Bowman was later indicted and pleaded guilty to conversion of property and related crimes, with a money judgment of forfeiture reflecting the proceeds of his theft, much of which was attributable to Cannon’s safe. After Bowman’s conviction and forfeiture proceedings, Cannon pleaded guilty to drug-trafficking charges and agreed to forfeit $366,800, the amount remaining after Bowman’s theft. Despite awareness of the larger sum, the government never initiated forfeiture proceedings for the stolen $218,200. Cannon subsequently filed a motion under Federal Rule of Criminal Procedure 41(g) for the return of the un-forfeited cash. The United States District Court for the Central District of California treated Cannon’s motion as a civil complaint and granted summary judgment for the government. The district court concluded that Cannon had agreed to forfeit all property seized and found his evidence regarding lawful possession of some of the funds insufficient. Upon appeal, the United States Court of Appeals for the Ninth Circuit reversed the district court’s decision. The Ninth Circuit held that sovereign immunity does not bar a Rule 41(g) claim for the return of cash when the government has recovered money traceable to funds it lost, even if it is not the exact physical currency seized. The court determined that Cannon had provided evidence of lawful sources for some of the cash and that the government had not rebutted this evidence sufficiently. The panel remanded the case for further proceedings to determine the proper disposition of the recovered funds. View "CANNON V. USA" on Justia Law

USA v. Turner

2026-06-29T08:00:45-08:00

Malaia Turner was indicted for conspiring to distribute 500 grams or more of methamphetamine. Evidence at trial showed that Turner and Marcus Posey operated a methamphetamine transportation and distribution scheme between California and Illinois, beginning in 2019. Turner was involved in purchasing, packaging, and shipping methamphetamine, recruiting couriers, and handling transactions. She and Marcus expanded their operations to include other individuals as couriers and negotiated deals for others. Turner also enforced payments from customers and handled large transactions herself. The evidence indicated that Turner and Marcus eventually split proceeds and consulted on pricing. The United States District Court for the Central District of Illinois conducted Turner’s jury trial, which resulted in her conviction. Prior to sentencing, the probation officer prepared a Presentence Investigation Report (PSR) recommending a two-level leader-organizer enhancement under U.S.S.G. § 3B1.1(c) and attributing substantial drug quantities to Turner. Turner objected to the drug amounts and the role enhancement in a sentencing memorandum. At the sentencing hearing, the district court overruled Turner’s objections to the PSR’s drug quantity calculations and the leader-organizer enhancement, adopted the factual findings, and sentenced Turner to 324 months’ imprisonment. Turner appealed, arguing procedural errors in the sentencing process and improper application of the enhancement. The United States Court of Appeals for the Seventh Circuit reviewed the district court’s factual findings for clear error and legal conclusions de novo. The Seventh Circuit held that the district court properly applied the two-level leader-organizer enhancement based on Turner’s supervisory role and involvement in the conspiracy. The court also found no error in the adoption of drug quantities, concluding that any procedural error was harmless because the sentence would not have been affected. The Seventh Circuit affirmed the district court’s judgment. View "USA v. Turner" on Justia Law

Chatrie v. United States

2026-06-29T07:15:07-08:00

A man robbed a credit union in Midlothian, Virginia in May 2019. Police learned from witnesses and surveillance that the robber appeared to use a cell phone but could not identify him. To find leads, the officers applied for a geofence warrant, compelling Google to provide anonymized location data for all cell phones within a 150-meter radius of the credit union around the time of the crime. The warrant described a three-step process: first, Google would produce anonymized data for all devices within the geofence for an hour; second, police would narrow the list and receive additional location data for those devices; third, police would further narrow the list and obtain identifying information. Ultimately, Google provided the identities of three users, including the petitioner, whose movements matched those of the robber. The United States District Court for the Eastern District of Virginia found the geofence warrant “plainly violates the rights enshrined in [the Fourth] Amendment” but denied the motion to suppress the evidence, applying the good-faith exception to the exclusionary rule. A divided panel of the United States Court of Appeals for the Fourth Circuit affirmed, but on the ground that no Fourth Amendment search had occurred because the petitioner had no reasonable expectation of privacy in the Location History data given to Google. On rehearing en banc, the Fourth Circuit affirmed in a one-sentence opinion, dividing evenly on the search question. The Supreme Court of the United States held that police conduct a Fourth Amendment search when they acquire an individual’s cell-phone Location History data from Google, because a person has a reasonable expectation of privacy in such information. The Court vacated the Fourth Circuit’s judgment and remanded the case for further proceedings to determine whether the warrant satisfied the Fourth Amendment’s requirements of particularity and probable cause at each stage of the search process. View "Chatrie v. United States" on Justia Law

State v. Lee

2026-06-29T06:10:40-08:00

A Moorestown restaurant was burglarized twice in September 2018. Security footage showed an intruder wearing a distinctive two-tone hooded sweatshirt taking or attempting to take cash from under the register. Police lifted five latent fingerprints from the register and a pizza oven after the incidents. Those prints were analyzed using the ACE-V method and compared against the Automated Fingerprint Identification System (AFIS), which led to the identification of the defendant as the suspected source. Fingerprint evidence was the only direct link between the defendant and the burglaries. The Superior Court, Appellate Division, reviewed the case after the defendant was convicted at trial. The defendant argued pretrial that the fingerprint evidence was unreliable, citing the National Academy of Sciences (NAS) and President’s Council of Advisors on Science and Technology (PCAST) reports. The trial court denied the motion to bar expert fingerprint testimony without holding a hearing. The Appellate Division reversed the convictions, finding reversible error in the trial court’s failure to conduct a pretrial hearing on reliability under N.J.R.E. 702. It also held there was an abuse of discretion in not questioning prospective jurors about fingerprint evidence during voir dire and error in allowing lay witnesses to offer subjective interpretations of surveillance footage. Upon appeal, the Supreme Court of New Jersey held that trial courts must ensure the reliability of expert testimony before it is presented to the jury and agreed a hearing on the fingerprint evidence was necessary. The Court appointed a Special Adjudicator to conduct a hearing to evaluate reliability and any necessary limitations. The Court retained jurisdiction, declined to reverse the conviction at this time, and reserved judgment on the voir dire and narration testimony issues pending the hearing’s outcome. View "State v. Lee" on Justia Law

People v. Lua

2026-06-26T13:02:51-08:00

The defendant was charged with two counts of carjacking and one count of reckless evasion, along with prior conviction enhancements. A jury convicted him of the carjacking charges, and the trial court found the enhancements true. In 2008, he was sentenced to an aggregate term of 28 years and four months, which included the upper term for the principal carjacking count, based on several aggravating factors such as threat of bodily harm, violent conduct, multiple prior convictions, commission of the crime while on parole, and unsatisfactory parole performance. After legislative changes retroactively invalidated certain prison prior enhancements, the defendant became eligible for resentencing under California Penal Code section 1172.75. The Superior Court of San Bernardino County struck some priors and resentenced him in 2024, ultimately reducing his sentence to 21 years and four months, but reimposed the upper term sentence for the principal count. The court discussed and relied on aggravating circumstances, including those previously cited and additional ones, and determined that the aggravating factors outweighed any mitigating factors. The defendant argued that, under current law, the court was required to have aggravating factors found true beyond a reasonable doubt or stipulated, but the resentencing court concluded that section 1172.75(d)(4) allowed reimposition of the original upper term without such findings. The California Court of Appeal, Fourth Appellate District, Division Two reviewed the case. It held that section 1172.75(d)(4) creates an exception permitting resentencing courts to reimpose an original upper term sentence without factual findings by a jury or stipulation, even if the court considers additional or different aggravating factors. The court further held that the Sixth Amendment is not violated under these circumstances, given the original sentence was imposed under a statutory scheme compliant with constitutional requirements at the time. The judgment was affirmed. View "People v. Lua" on Justia Law

State v. Thornton

2026-06-26T12:36:52-08:00

Two men were convicted in the Circuit Court for Baltimore City on charges related to the 2019 murder of Donnell Brockington, who was surrounded and fatally shot multiple times by a group of six individuals. After the suspects fled, four, including the two respondents, were apprehended when their vehicle crashed. Police recovered several firearms, and DNA evidence linked both respondents to a Desert Eagle 9mm pistol found in the vehicle. At trial, a State firearms examiner testified that certain ammunition components were fired from that pistol, but neither respondent challenged the reliability of the examiner’s methodology or requested a Daubert hearing. After trial, the Supreme Court of Maryland decided Abruquah v. State, clarifying the limits on firearms identification testimony. The Appellate Court of Maryland reversed the respondents’ convictions on plain-error review, concluding that the firearms examiner’s unqualified testimony was exactly the kind prohibited by Abruquah. Additionally, one respondent challenged the trial court’s decision to close the courtroom during jury deliberations and partially restrict attendance during the verdict, arguing it violated the Sixth Amendment. The Appellate Court found these closures de minimis and rejected the public trial claim. The Supreme Court of Maryland held that the admission of the firearms examiner’s unqualified opinion was not “clear or obvious” error for plain-error review purposes, since the law was unsettled both at trial and on appeal; Abruquah was a case-specific ruling, not a categorical ban on such testimony. The Court also concluded that the courtroom closures were not de minimis but were justified under Waller v. Georgia, given the trial court’s findings of escalating spectator misconduct and concern for juror safety. The Supreme Court reversed the Appellate Court’s judgment on the convictions, affirmed its ruling on the public trial issue, and remanded for further proceedings. View "State v. Thornton" on Justia Law

US v. Colon-Vazquez

2026-06-26T12:00:02-08:00

The case concerns a man who was found sleeping in a stolen vehicle by Puerto Rican police. Upon investigation, officers discovered that he possessed three firearms, two of which had been modified to function as machineguns, as well as a large quantity of ammunition, high-capacity magazines, ski masks, gloves, and other items often associated with criminal activity. He was charged with one count of possession of a machinegun under federal law and pled guilty pursuant to a plea agreement. The plea agreement anticipated a lower offense level and allowed the defendant to argue for an eighteen-month sentence, while the government agreed not to recommend more than twenty-four months. However, the United States Probation Office prepared a presentence report calculating a higher offense level, resulting in a Guidelines sentencing range of thirty to thirty-seven months. The defendant did not object to this calculation. At sentencing in the United States District Court for the District of Puerto Rico, both parties presented arguments, and the defendant personally expressed remorse. The district court, after reviewing the facts, the presentence report, and the parties' arguments, imposed a forty-eight-month sentence, representing an eleven-month upward variance from the Guidelines range. The court cited the quantity and type of firearms and ammunition, the presence of items commonly used in violent crime, and the high rate of violent crime in Puerto Rico as justifications for the variance. The United States Court of Appeals for the First Circuit reviewed the case. The court held that the district court did not commit procedural or substantive error. It found that the upward variance was adequately explained and justified, particularly by the significant quantity of ammunition and high-capacity magazines, and was consistent with precedent. The First Circuit affirmed the forty-eight-month sentence. View "US v. Colon-Vazquez" on Justia Law

United States v. Lineback

2026-06-26T11:30:46-08:00

A 17-year-old grocery store employee in Tipton County, Tennessee, was approached by a regular customer, Austin Lineback, who took a photo of him and later sent edited pictures depicting the boy’s face superimposed onto female bodies, along with text messages that included compliments and an invitation to Lineback’s house. Concerned by these communications, the minor and his mother contacted law enforcement. Detective Bruno sought and obtained a warrant to search Lineback’s home, citing the photos, texts, and Lineback’s status as a registered sex offender with prior convictions for sexual offenses involving minors. The search uncovered writings and materials expressing sexual interest in minors, a photo album and photographs of apparent minors in provocative poses, and electronic devices. A subsequent search of these devices revealed two verified images of child pornography in a folder labeled “Nude Boys.” At the United States District Court for the Western District of Tennessee, Lineback moved to suppress the evidence, arguing the initial warrant lacked probable cause and that any evidence from the electronic search was tainted as a result. The district court denied both the motion to suppress and a later motion for judgment of acquittal based on sufficiency of the evidence. After a jury trial, Lineback was found guilty on one count of knowingly possessing child pornography. The United States Court of Appeals for the Sixth Circuit reviewed the district court’s decisions de novo and affirmed. The court held that the warrant to search Lineback’s home was supported by probable cause, considering the totality of the circumstances, including his prior convictions and the nature of the communications with the minor. The appellate court also found sufficient evidence for a rational jury to conclude that Lineback knowingly possessed child pornography, given the corroborating circumstantial evidence and the verified images. The conviction was affirmed. View "United States v. Lineback" on Justia Law

Bracey v. Superintendent Rockview SCI

2026-06-26T09:00:11-08:00

In 1995, a man was convicted by a jury in the Dauphin County Court of Common Pleas for first-degree murder following the shooting death of another individual related to a drug deal. Two key prosecution witnesses, both facing pending charges themselves, testified against him in exchange for plea agreements. The prosecution did not disclose all pending charges against these witnesses, though defense counsel was able to impeach their credibility based on other known charges. Despite this, the jury convicted the defendant, who was sentenced to life imprisonment. He unsuccessfully challenged his conviction on direct appeal and through multiple post-conviction proceedings in state court. After eventually discovering the full extent of the witnesses' pending charges, the petitioner filed a federal habeas petition under 28 U.S.C. § 2254 in the United States District Court for the Middle District of Pennsylvania, asserting a Brady violation. The District Court denied the petition as untimely under the statute of limitations, and subsequent requests for a certificate of appealability were also denied. Following a significant change in Third Circuit law announced in Dennis v. Secretary, Pennsylvania Department of Corrections, the petitioner sought to reopen his federal habeas case under Federal Rule of Civil Procedure 60(b)(6). After a remand for further analysis, the District Court again denied the Rule 60(b)(6) motion, finding that the factors for extraordinary relief were not met. The United States Court of Appeals for the Third Circuit reviewed the denial, applying an abuse-of-discretion standard and weighing the Cox factors. The Court held that, although the materiality and diligence factors favored the petitioner, the remaining factors—likelihood of success, finality and comity, lack of actual innocence, and non-capital sentence—strongly disfavored relief. The Third Circuit affirmed the District Court’s denial of the Rule 60(b)(6) motion. View "Bracey v. Superintendent Rockview SCI" on Justia Law

USA v. Johnson

2026-06-26T07:30:46-08:00

Brian Johnson orchestrated a fraudulent scheme from 2010 onward, in which he posed as both the CEO and an employee of a fictitious adult film, photography, and art studio. He posted advertisements online, soliciting women to audition for purported modeling or adult film opportunities, promising substantial compensation and future work. Johnson required in-person meetings, during which he took nude photographs and videos, gave the women alcohol, and engaged in sexual acts with them. He falsely claimed their images needed to be reshot for a distributor and threatened to post the images online if they refused further participation. One victim, who was sixteen at the time, eventually revealed her true age and provided proof, but Johnson continued to possess and distribute her images. The United States District Court for the Northern District of Illinois, Eastern Division, conducted the trial. A jury convicted Johnson on seven counts of sex trafficking and three counts of child pornography. Johnson moved for acquittal post-trial; the district court denied his request regarding the sex trafficking convictions but granted acquittal on the child pornography convictions. Johnson was sentenced to 420 months in prison. Both Johnson and the government appealed: Johnson challenged his convictions and sentence, while the government cross-appealed the acquittal on the child pornography counts. The United States Court of Appeals for the Seventh Circuit reviewed the case. The court affirmed the district court’s denial of Johnson’s motion for acquittal on the sex trafficking convictions, holding that fraudulent promises of future compensation and work opportunities can constitute “things of value” under 18 U.S.C. § 1591(e)(3) when the victims subjectively believe in their value. The court found the sentence substantively reasonable. However, it reversed the district court’s acquittal on the child pornography convictions, concluding that sufficient evidence supported the jury’s findings regarding Johnson’s knowledge of the victim’s age. The court vacated the sentence and remanded for reinstatement of the child pornography convictions and resentencing. View "USA v. Johnson" on Justia Law

State v. Carr

2026-06-26T06:34:56-08:00

Two defendants were convicted of multiple counts of capital murder and other crimes following a violent crime spree in Wichita. The State charged each defendant with eight counts of capital murder, using two alternative theories for each victim: intentional killing of a rape victim and intentional killing of more than one person in the same act. Both defendants were tried jointly, found guilty on all eight capital-murder counts, and sentenced to death for four merged convictions, one for each victim. The Kansas Supreme Court initially reviewed the case, affirming one capital-murder conviction per defendant, reversing others due to instructional errors and multiplicity. The court vacated the death sentences, finding joint penalty-phase proceedings violated the Eighth Amendment. The United States Supreme Court, in Kansas v. Carr, reversed this Eighth Amendment holding and remanded. Upon remand, the Kansas Supreme Court reviewed remaining penalty-phase issues and affirmed each defendant’s death sentence for the four victims. After these appellate mandates issued, both defendants moved for new sentencing hearings, arguing unresolved issues remained and that their sentences, especially for non-capital convictions, were illegal or improperly imposed. The Sedgwick District Court denied these motions, finding no jurisdiction or outstanding issues under the mandates. The Supreme Court of the State of Kansas held that the mandates reflected final appellate judgments affirming the death sentences, leaving no unresolved capital-sentencing issues for the district court. The court also held that the mandate rule barred new legal challenges to non-capital convictions and sentences raised post-mandate. Statutory authority to notice unassigned errors or correct illegal sentences did not apply to these new claims. The district court’s denial of post-mandate sentencing motions was affirmed. View "State v. Carr" on Justia Law

State v. N. K. B.

2026-06-26T05:53:53-08:00

A woman, referred to as Naomi, was charged with felony battery by a prisoner after slapping a nurse while incarcerated in the Milwaukee County jail. At her initial court appearance, concerns were raised about her competency to stand trial, and the Milwaukee County Circuit Court ordered a competency evaluation. Upon finding Naomi incompetent but likely to regain competence with treatment, the court committed her to the Department of Health Services (DHS) for treatment. The court originally found her incompetent to refuse medication and, after applying the standards from Sell v. United States, ordered involuntary medication to restore competency. Naomi appealed, and the court stayed the order. Subsequently, after DHS raised concerns about Naomi’s dangerousness, the court vacated its earlier order and issued a new involuntary medication order based solely on Naomi’s dangerousness, relying on WIS. STAT. § 51.61(1)(g)3. Naomi challenged the legal authority for this order, arguing that someone committed only under WIS. STAT. § 971.14 for competency restoration could not be involuntarily medicated on dangerousness grounds under § 51.61(1)(g)3. The Wisconsin Court of Appeals agreed with Naomi, rejecting the State’s arguments that various statutory and case law authorities permitted the order. The Supreme Court of Wisconsin reviewed the matter and affirmed the Court of Appeals. The court held that WIS. STAT. § 51.61(1)(g)3. does not authorize a court to order involuntary medication for an individual committed exclusively under WIS. STAT. § 971.14. The court based its decision on statutory language, context, and history, finding that § 971.14 provides a separate, more stringent process for involuntary medication orders in the context of competency restoration, and that § 51.61(1)(g)3. cannot be used as an alternative basis for such orders. View "State v. N. K. B." on Justia Law