Justia Criminal Law Opinion Summaries

The case involves a challenge to the constitutionality of several Nevada statutes regulating "ghost guns," or unfinished firearm frames or receivers. The respondent, Polymer80, Inc., a manufacturer of gun-related products, argued that the definition of "unfinished frame or receiver" in the statutes was impermissibly vague, making the statutes unconstitutional. The district court agreed with Polymer80, concluding that the definition did not clearly explain key terms or notify individuals when raw materials would become an unfinished frame or receiver. The court also found that the definition allowed for arbitrary and discriminatory enforcement.The Supreme Court of the State of Nevada disagreed with the lower court's findings. The court found that the terms used to define "unfinished frame or receiver" had ordinary meanings that provided sufficient notice of what the statutes prohibited. The court also concluded that the statutes were general intent statutes that did not lack a scienter requirement and did not pose a risk of arbitrary or discriminatory enforcement. Therefore, the court reversed the district court's decision, holding that the statutes were not unconstitutionally vague. View "Sisolak v. Polymer80, Inc." on Justia Law

The case involves a minor, D.C. Jr., who was charged with murder, attempted murder, and robbery. D.C. Jr., who has an IQ of 66, was 14 years old at the time of the alleged crimes. His counsel requested a competency determination before proceeding to the certification hearing. After an initial finding of incompetency followed by competency-restoration sessions, the juvenile court declared D.C. Jr. competent to proceed. However, the court did not explicitly address the conflicting expert testimony regarding D.C. Jr.'s understanding of the proceedings and ability to assist counsel.The juvenile court certified D.C. Jr. for prosecution as an adult. The court's decision was based on the assumption that the competency standards for juvenile court applied, which was a mistake. The court did not adequately support its determination with findings, and it appears to have applied an incorrect standard.The Supreme Court of Nevada vacated the certification order and the competency determination. The court held that a juvenile facing the possibility of prosecution as an adult on serious criminal charges must meet the adult criminal court standard for competence. The court remanded the case for the juvenile court to reassess D.C. Jr.'s competency using the correct standard. The court emphasized that the stakes were high, and the record did not show that the juvenile court correctly assessed D.C. Jr.'s competency to proceed. The court also vacated the order certifying D.C. Jr. for criminal proceedings as an adult, which followed the competency determination. View "In re D.C." on Justia Law

The case involves Ricardo Perez-Delgado, who was sentenced to forty years in prison for his role in a violent robbery that resulted in the death of a businessman. The sentence was significantly higher than the guideline sentencing range (GSR), which had a maximum of thirty years and five months. Perez-Delgado appealed, arguing that the district court did not adequately explain its rationale for imposing a sentence nearly a decade over the top of the GSR.The district court had adopted the probation office's GSR calculation and considered the relevant statutory factors, Perez-Delgado's background, the nature and circumstances of the offense, and the arguments of both parties. However, the court's explanation for the upward variance was limited to a single sentence stating that the recommended sentence did not reflect the seriousness of the offense, promote respect for the law, protect the public from further crimes by Perez-Delgado, or address issues of deterrence and punishment.The United States Court of Appeals for the First Circuit agreed with Perez-Delgado's argument. The court found that the district court's explanation was insufficient to justify the significant upward variance from the GSR. The court noted that the greater the variance, the greater the explanation must be. The court vacated Perez-Delgado's sentence and remanded the case for resentencing, instructing the district court to provide an individualized explanation proportional to the length of the variance if it decided to upwardly vary again. View "United States v. Perez-Delgado" on Justia Law

Antonio Davis, who was serving a 210-month prison sentence for conspiracy to possess with intent to distribute heroin, petitioned the district court for compassionate release due to his elevated risk of severe COVID-19 and a change in the law regarding his career offender status. The district court denied his request, concluding that Davis was not due compassionate release based on his susceptibility to COVID-19 and did not fully consider each of Davis’s arguments.Davis was indicted on charges of conspiracy to distribute and conspiracy to possess with intent to distribute heroin in January 2013. He pled guilty to conspiracy to possess with intent to distribute heroin in June of that year. Davis received a career offender enhancement because he had previously been convicted of certain other offenses and because the offense at issue here was a “controlled substance offense” at the time of conviction. In February 2021, Davis filed a pro se motion for compassionate release under 18 U.S.C. § 3582(c)(1)(A), arguing that he was uniquely susceptible to the potential spread of COVID-19 due to his type-2 diabetes and hypertension. He also argued that a recent court decision invalidated his career offender Guidelines designation.The United States Court of Appeals for the Fourth Circuit affirmed in part, vacated and remanded in part the district court's decision. The court concluded that the district court did not abuse its discretion in finding that Davis failed to show extraordinary and compelling reasons for release based on the pandemic. However, the court found that the district court did not properly address Davis’s arguments regarding intervening changes in law and rehabilitation. Therefore, the court vacated the district court’s denial of compassionate relief and remanded for further proceedings. View "United States v. Davis" on Justia Law

The case revolves around Victor Ramirez, who was pulled over by police officers for traffic violations. Recognizing Ramirez as a gang member from a previous encounter, one of the officers asked him about his parole status. Ramirez confirmed he was on parole for a firearm-related offense. During the stop, the officers discovered a loaded firearm in Ramirez's car. Ramirez was subsequently indicted for possessing a firearm and ammunition as a felon.Ramirez moved to suppress the gun and ammunition, arguing that the officers unreasonably prolonged the stop by asking about his parole status, which he claimed was unrelated to the traffic stop. The district court denied Ramirez's motion to suppress, and Ramirez pleaded guilty to possessing a firearm and ammunition as a felon, reserving his right to challenge the denial of his motion to suppress.The United States Court of Appeals for the Ninth Circuit affirmed the district court's decision. The court held that asking about parole status during a traffic stop does not violate the Fourth Amendment as it reasonably relates to the officer's safety and imposes a negligible burden. The court also remanded the case in part so that the district court could correct the written judgment to conform it to the oral pronouncement of sentence. View "United States V. Ramirez" on Justia Law

The case involves Andrew Bertrand, who was convicted of two counts of first-degree child molestation. Bertrand argued that his counsel was ineffective for failing to propose lesser included offense instructions on fourth-degree assault. The trial court denied Bertrand's motion, ruling that although counsel was deficient for purposes of Strickland’s first prong, Bertrand could not show prejudice as required by Strickland’s second prong. The trial court ruled that because the State had met its burden of proving each element of first-degree child molestation and the jury convicted Bertrand of those charges, he could not show prejudice.The Supreme Court of the State of Washington clarified that a defendant can show ineffective assistance based on counsel’s failure to propose a lesser included offense instruction, even if there is sufficient evidence to support the jury’s verdict. However, the court affirmed the trial court's decision, stating that Bertrand was not prejudiced by his counsel’s failure to propose the fourth-degree assault instructions. The court remanded the remaining issues to the Court of Appeals for further proceedings. View "State v. Bertrand" on Justia Law

The case involves an action filed by Spokane County Prosecuting Attorney Lawrence Haskell against Jilma Meneses, the secretary of the Washington State Department of Social and Health Services (DSHS). The Prosecutor sought a writ of mandamus directing Meneses to comply with statutory duties under chapter 10.77 RCW and timely provide competency services in criminal proceedings. The case specifically concerned three categories of Spokane County defendants in felony criminal proceedings ordered to receive competency services from DSHS.Previously, a class action was filed in federal court, challenging DSHS's delays in providing competency services to criminal defendants in pretrial custody. The United States District Court for the Western District of Washington held these delays violated the class members’ due process rights and issued a permanent injunction against DSHS. The injunction set strict time limits for providing competency services to defendants in pretrial custody, appointed a special court monitor, and began oversight of DSHS’s efforts to comply with the injunction.In the Supreme Court of the State of Washington, DSHS argued that the court must dismiss the petition for lack of original jurisdiction because the secretary is not a state officer within the meaning of the state constitution. The court agreed with DSHS, concluding that the secretary is not a state officer. The court reasoned that a state officer must be elected, subject to impeachment, and granted a State sovereign power, none of which applied to the secretary. Therefore, the court dismissed the petition for writ of mandamus. View "Spokane County v. Meneses" on Justia Law

In October 2019, Max Bolden shot and killed Benjamin Donahue outside a club in Sioux Falls, South Dakota. Bolden was indicted for first-degree murder, second-degree murder, and possession of a firearm by a convicted felon. At trial, Bolden claimed that he shot Donahue in self-defense. The circuit court denied Bolden's motions for a judgment of acquittal on the murder charges. The jury found Bolden guilty of first-degree murder and possession of a firearm by a convicted felon. Bolden appealed his first-degree murder conviction on the grounds of insufficient evidence.The Supreme Court of the State of South Dakota affirmed the lower court's decision. The court found that there was sufficient evidence to support the jury's verdict. The court noted that Bolden had used a gun to shoot Donahue point blank in the face without provocation, and then shot him again while he was lying on the ground. The court also pointed out that Bolden had immediately left the scene, fled the state, and disposed of the gun used to shoot Donahue. The court concluded that a rational trier of fact could have found the essential elements of first-degree murder beyond a reasonable doubt. View "State v. Bolden" on Justia Law

Tyrone Cameron was convicted of being a felon in possession of ammunition following a three-day trial. The district court sentenced him to 120 months' imprisonment and a three-year term of supervised release. Cameron appealed, arguing that there was insufficient evidence to support his conviction, that his conviction violated the Second Amendment, that the district court should not have admitted his prior felony convictions involving firearms into evidence, and that the government engaged in prosecutorial misconduct during closing arguments.The district court had reviewed the evidence, including surveillance footage and testimonies, and found sufficient circumstantial evidence to support Cameron's conviction. The court also admitted Cameron's prior felony convictions into evidence, which were relevant to show that Cameron knew he was a felon and knowingly possessed ammunition.The United States Court of Appeals for the Eighth Circuit affirmed the district court's decision. The court found that a reasonable jury could have found there existed ample circumstantial evidence to support Cameron’s conviction. The court also rejected Cameron's Second Amendment challenge, noting that the Supreme Court's decision in New York State Rifle & Pistol Ass’n, Inc. v. Bruen did not cast doubt on longstanding prohibitions on the possession of firearms by felons. The court found no error in the district court's admission of Cameron's prior felony convictions, as they were relevant to the case and not unfairly prejudicial. Lastly, the court found no prosecutorial misconduct, as the government's remarks during closing arguments were permissible interpretations of the evidence. View "United States v. Tyrone Cameron" on Justia Law

The case involves Roger Ouellette, who was convicted of Operating Under the Influence (OUI) following a police stop in his driveway. The police officer had observed Ouellette's vehicle crossing the center line of the road, which led the officer to suspect a violation of traffic laws. Ouellette entered a conditional guilty plea after his motion to suppress evidence obtained from the stop was denied by the trial court.The trial court found that the officer had reasonable suspicion to stop Ouellette due to his observed traffic violation. Ouellette argued that the stop was unjustified as the officer lacked reasonable suspicion of wrongdoing. However, the court determined that the stop was supported by reasonable articulable suspicion that Ouellette had violated the motor vehicle statute requiring vehicles to be operated within a single lane.On appeal, Ouellette argued that the stop was an unreasonable seizure under the Fourth Amendment because it occurred within the curtilage of his home without a warrant and without any applicable exception to the warrant requirement. The Maine Supreme Judicial Court affirmed the lower court's decision, concluding that the court's failure to grant Ouellette’s motion on that ground did not constitute obvious error and that the stop was justified based on reasonable suspicion. The court also found that Ouellette's argument regarding the stop occurring within the curtilage of his home was unpreserved and did not amount to obvious error. View "State of Maine v. Ouellette" on Justia Law