Justia Criminal Law Opinion Summaries

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The Supreme Court of New Hampshire reviewed the case of Kierran Pierce, who appealed his convictions of aggravated felonious sexual assault (AFSA) and attempted AFSA. Pierce argued that the trial court erred in denying his motions for a mistrial and to dismiss the attempted AFSA charge at the close of the State's case. The Supreme Court concluded that the trial court did indeed err in denying the request for a mistrial. The court found that a statement made during the trial, indicating that Pierce had allegedly touched multiple children inappropriately, was highly prejudicial and should have resulted in a mistrial.However, the Supreme Court upheld the trial court's denial of the motion to dismiss the attempted AFSA charge, as they found sufficient evidence to prove guilt. The court reasoned that, despite alternative explanations presented by the defendant, the evidence supported the conclusion that the defendant was attempting to commit an act of sexual assault.The Supreme Court also briefly addressed the trial court's denial of the defendant's request for a view of the residence where the alleged sexual assaults occurred. The court did not make a definite ruling on this issue, suggesting instead that the parties might wish to develop these facts further in any subsequent trial. The case was ultimately reversed and remanded for further proceedings. View "State v. Pierce" on Justia Law

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The case revolves around Eric Boudette, who was convicted of Driving Under the Influence of Alcohol, First Offense, following a jury trial on May 31, 2022. Boudette appealed the verdict, asserting that his motion to dismiss for prosecutorial misconduct was wrongly denied. He also contended that his plea for a new trial was wrongly denied on the grounds that his arrest was an unlawful seizure, the Justice Court lacked jurisdiction to try the case, and the statutory speedy trial deadline had expired by the time his trial was held.The Supreme Court of the State of Montana reviewed the case following Boudette's appeal against the District Court's affirmation of the Justice Court's decision. The Supreme Court analyzed several aspects of the case, including jurisdiction, the Community Caretaker Doctrine, allegations of prosecutorial misconduct, and the speedy trial issue.The Court ruled that Boudette could rightfully be charged in either county where he was found driving under the influence. They also determined that the arresting officer acted in her capacity as a community caretaker when she entered Boudette's vehicle to check on his wellbeing, thus making the arrest lawful. Regarding the allegations of prosecutorial misconduct, the Court found no evidence of perjury or the State unreasonably impeding Boudette from obtaining an independent blood test. Lastly, the Court declared that Boudette had waived his right to a speedy trial by requesting a continuance.Hence, the Supreme Court of the State of Montana affirmed the District Court’s decision. View "State v. Boudette" on Justia Law

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The case arose from appellant Khamal Fooks' claim that his attorney misled him about the parole eligibility related to his plea agreement. Fooks had pleaded guilty to third-degree murder, conspiracy, and carrying an unlicensed gun in a Pennsylvania state court. He later alleged that his lawyer incorrectly assured him he would be eligible for parole after ten years, when in reality, he had to serve at least twenty. His allegations, if true, would demonstrate that his lawyer’s advice was ineffective.Both the state and the federal district courts dismissed his claims without providing an opportunity for an evidentiary hearing. Fooks then appealed this decision to the United States Court of Appeals for the Third Circuit. The Circuit Court found that Fooks' allegations, if proven, would indeed establish ineffective assistance of counsel, thereby warranting habeas relief.The Circuit Court held that the district court erred in not affording Fooks an evidentiary hearing to substantiate his allegations. The court emphasized the importance of giving petitioners a fair chance to prove their allegations and remanded the case for an evidentiary hearing. The court did not rule on Fooks' entitlement to relief, instead emphasizing the need for a fair opportunity to present evidence supporting his claims. View "Khamal Fooks v. Superintendent Smithfield SCI" on Justia Law

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The case revolves around the defendant, Antonio S. Davis, who was charged with misdemeanor battery and disorderly conduct. Davis had applied for representation from the State Public Defender (SPD) and while his application was still being processed, he was arraigned. Consequently, Davis pleaded not guilty and further proceedings were scheduled. It was not until 65 days later that the SPD appointed counsel for Davis. Six days after counsel was appointed, Davis filed a request for substitution of judge, which was denied by the Circuit Court for Dane County as untimely.Davis then filed a petition for supervisory writ, arguing that the Circuit Court had a plain duty to treat his request for substitution of judge as timely. The Court of Appeals denied his petition and the case was brought before the Supreme Court of Wisconsin for review. The Supreme Court needed to decide whether Davis had forfeited the issues he brought forth and whether he was entitled to a supervisory writ directing the lower court to treat his request for substitution of judge as timely.The Supreme Court concluded that even if Davis had forfeited the issues, they would exercise discretion to address them to clarify the procedure for appealing a denial of a request for substitution of judge as untimely. However, the court found that Davis was not entitled to a supervisory writ, asserting that the lower court did not have a plain duty to treat Davis's request as timely under Wisconsin Statute § 971.20(4), Dane County Local Rule 208, a government-created obstacle exception, or a theory of equitable tolling. The Supreme Court affirmed the decision of the Court of Appeals and remanded the case for further proceedings. View "Davis v. Circuit Court for Dane County" on Justia Law

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In the appeal case presented, the defendants, Brian Terrell Hill and Clifford Jenkins, sought resentencing under Penal Code section 1172.6 for their convictions of first-degree murder and attempted murder. The defendants were initially convicted based on their involvement in the 1990 kidnapping and subsequent murder of Randy Burge and attempted murder of Kevin Thomas.The defendants contended that their petitions for resentencing were denied based on a felony murder theory related to kidnapping, which they argued violated ex post facto principles. They stated that at the time of the offense, kidnapping was not an enumerated felony under section 189, subdivision (a) to which felony-murder liability could be attached. However, the court rejected this argument, stating that section 1172.6 does not apply new law retroactively to make formerly innocent conduct criminal, but looks to whether a defendant could be convicted under current law.The court found substantial evidence supporting the lower court's determination that Hill intended to kill Thomas and was therefore guilty of attempted murder. Similarly, the court found substantial evidence supporting the lower courts' findings that both Hill and Jenkins were guilty of felony murder as major participants in the kidnapping who acted with reckless indifference to human life.Given these findings, the court affirmed the denial of Hill's and Jenkins' petitions for resentencing under Penal Code section 1172.6. View "People v. Hill" on Justia Law

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The United States Court of Appeals for the Fourth Circuit affirmed the district court's decision that the Federal Bureau of Investigation (FBI) could withhold records relating to a criminal investigation based on Exemption 7(A) of the Freedom of Information Act (FOIA). This exemption allows federal agencies to withhold records if their release could reasonably be expected to interfere with law enforcement proceedings.In the case, Mark Zaid, an attorney, requested records related to the FBI's criminal investigation into one of his clients, Zackary Sanders, who had been charged with production and possession of child pornography. The FBI refused to release the requested records, citing Exemption 7(A) of FOIA. Zaid then sued the FBI to release the records, but the district court found the records were exempt from disclosure.The appeals court agreed with the district court's decision, stating that the disclosure of these records could reasonably be expected to interfere with ongoing or future investigations and prosecutions of child pornography cases. The court also noted that forcing the FBI to disclose information exchanged between law enforcement agencies could make those agencies hesitant to share information in the future, which would harm FBI investigations. The court also dismissed Zaid's arguments that cited two decisions from the Middle District of Florida, stating those decisions were not binding on the district court or the appeals court. View "Zaid v. Department of Justice" on Justia Law

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The Supreme Court of Maryland held that the State's duty to preserve scientific identification evidence, such as DNA, is limited to specific crimes specified in the Criminal Procedure Article ("CP") § 8-201(j)(1)(ii) and does not extend to all crimes for which a person may petition for DNA testing. The Court ruled that the preservation obligation does not apply to the inchoate (or incomplete) offenses of those crimes listed under the same section of the law. The Court also found that the State's duty to preserve evidence does not extend to attempted murder.The case involved Darrell Eugene Matthews who had been convicted of attempted murder and was seeking post-conviction DNA testing of a glove found at the crime scene. The glove had been destroyed according to the police department's evidence retention policy after Matthews's first petition for DNA testing. The Court held that the circuit court correctly denied Matthews's second petition for post-conviction DNA testing because the State was not required to preserve evidence related to Matthews's attempted murder conviction for the duration of his sentence. The Court also found that the evidence Matthews sought to test had been destroyed in line with the police department's evidence retention policy. View "Matthews v. State" on Justia Law

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The case revolves around a murder conviction. On February 23, 2021, a bar shooting resulted in the death of Raymond Renteria-Hobbs and injury to another victim, M.P. Police identified Andrew Vernard Glover as the suspect based on security footage showing him at the bar on the night of the murder and his interactions with Renteria-Hobbs before the shooting. The police arrested Glover and, upon searching his residence, found the hat he wore on the night of the shooting, a loaded firearm, and ammunition.At trial, Glover challenged his arrest and the subsequent search of his residence. However, the court held that the police had probable cause to arrest Glover, and the search warrant application for his residence did not materially misrepresent information.Glover also sought to introduce evidence of prior crimes committed by an alleged alternative perpetrator, but the court denied his request, finding those crimes were neither relevant nor material to the charged offense. Glover also argued that the court violated his confrontation rights by denying his request to cross-examine the lead investigator about whether police had investigated unnamed suspects from a prior shooting of one of the victims. The court rejected this argument as well.The jury convicted Glover of first-degree murder during a drive-by shooting, drive-by shooting, and ineligible person in possession of a firearm. Glover appealed, but the Supreme Court of Minnesota affirmed the conviction. The court held that the police had probable cause to arrest Glover, the search of his residence was lawful, the court did not abuse its discretion by denying Glover's motion to admit reverse-Spreigl evidence, and Glover's confrontation rights were not violated. View "State of Minnesota vs. Glover" on Justia Law

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The Supreme Court of the State of Colorado affirmed a lower court's restitution order, ruling that the defendant was the proximate cause of the victim's pecuniary loss. The defendant, Arnold Roman Martinez, had stolen a bicycle and was pursued by the bicycle's owner in a car. The car was damaged when the owner cut off Martinez, causing him to crash into the car. The district court ordered Martinez to pay over $2,000 in restitution for the damage to the car.On appeal, Martinez challenged the order, asserting that he did not proximately cause the damage to the car. The Supreme Court of the State of Colorado ruled that the standard for reviewing a district court's determination of proximate cause for criminal restitution is clear error, not the abuse-of-discretion standard used by the lower court. The Supreme Court found that the district court did not clearly err in determining that Martinez's theft was the proximate cause of the damage to the car. Therefore, the Supreme Court affirmed the restitution order on different grounds. View "Martinez v. People" on Justia Law

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The Supreme Court of Colorado examined the case of Carlos Ray Maes, who was charged with six felony counts. A magistrate presided over the preliminary hearing and found that probable cause existed for each of the eligible counts. The case was then bound over to the district court. Nearly three months later, Maes petitioned the district court for a review of the magistrate's probable-cause determination, but the district court declined, arguing that it did not have jurisdiction to review such a determination and that Maes's petition was not timely.The Supreme Court of Colorado held that a magistrate's finding of probable cause after a preliminary hearing is a "final order or judgment" under the Colorado Rules for Magistrates and is therefore reviewable by a district court. Further, the court held that the time limit for petitioning for district court review of a magistrate's final order or judgment begins when the magistrate memorializes that determination in writing. Consequently, the court concluded that Maes's petition was timely filed. The court made the rule to show cause absolute and remanded the case for further proceedings consistent with its opinion. View "People v. Maes" on Justia Law