The Superior Court held that a juvenile’s admission to misdemeanor drug possession did not permit an automatic delinquency adjudication without evidence of a need for treatment, supervision, or rehabilitation.
The Superior Court held that a passenger’s nod and glance toward his waistband, combined with a stolen plate and the surrounding circumstances, gave police reasonable suspicion for a Terry frisk.
The Court of Appeals read the form and surrounding record as showing an effective dismissal only of the habitual-felon matter, not the jury’s assault verdict. The trial court had expressly held sentencing open, so it retained authority to enter judgment on the assault conviction. Evidence that Lofton took a route requiring him to jump a fence and discarded clothing while officers pursued him supported the flight inst
The Court of Appeals found no reversible error. The trial judge acted within the broad discretion used to manage voir dire and questioning, including limited leading questions to a minor testifying about sexual abuse. The panel found no plain error in the challenged evidence and no gross impropriety requiring intervention during argument. Because evidence admitted without reversible error could be discussed in closin
The Court of Appeals upheld denial of suppression. Evidence in plain view could be seized where officers were lawfully present and its evidentiary significance was immediately apparent in the violent-crime investigation then underway. Relying on North Carolina precedent involving later comparison of lawfully obtained genetic material, the panel also held that secondary DNA analysis imposed no new physical intrusion a
The Superior Court held that Greenlight app transaction screenshots were machine-generated data rather than hearsay and upheld a juvenile theft adjudication.
The Superior Court upheld a caretaker’s convictions for theft by deception and financial exploitation of an older adult based on checks obtained beyond her agreed compensation.
The Superior Court held that towing a stolen truck, without evidence the driver knew it was stolen before police stopped him, did not establish a prima facie case of receiving stolen property.
The Massachusetts SJC affirmed a first-degree murder conviction after finding four alleged investigative failures did not undermine the verdict.
The Utah Court of Appeals held that sufficient evidence supported a fatal negligent-driving conviction and that any speeding-instruction error was harmless.
The Utah Court of Appeals declined to overrule State v. Heath and affirmed object-rape and sexual-abuse convictions against evidentiary and due-process challenges.
The Utah Supreme Court affirmed child-sex-abuse convictions after finding waiver, inadequate preservation, and no deficient performance across multiple trial challenges.
The Massachusetts SJC held that a court seal and clerk’s stamped signature do not replace a written attestation that a docket copy is accurate.
The Superior Court held that multiple observations supplied reasonable suspicion to extend a traffic stop for a dog sniff and that the driver voluntarily consented to an interior search.
The Massachusetts SJC affirmed a new trial where witness records, third-party-culprit evidence, and modern DNA results collectively cast real doubt on a murder conviction.
The Supreme Court of Guam overruled its prior decision, holding that discovery did not satisfy GRE 404(b) notice, and reversed Philips James Sablan’s conviction.
The Wyoming Supreme Court affirmed Steven Randall Marler’s convictions on eight counts of sexual abuse and six counts of battery against children in his care, holding that the district court properly admitted broad Rule 404(b) “other acts” evidence of grooming rituals and a fear-based disciplinary regimen, that a victim’s collateral lie to a jail guard was excludable without violating the Confrontation Clause, that a rule-of-completeness claim was waived by failure to make an offer of proof, and that brief prosecutorial questioning about a victim’s father’s suicide did not constitute plain-error misconduct.
The Utah Court of Appeals affirmed a conviction for aggravated sexual abuse of a child, holding that Utah Rule of Evidence 404(c) requires no similarity between prior child molestation acts and the charged offense for propensity evidence to be admissible, and that trial counsel was not ineffective for retaining a juror whose troubling statements during voir dire were followed by an audible chuckle and an express affirmation of the presumption of innocence.
The Massachusetts Appeals Court vacated all judgments and set aside all verdicts in a child sexual abuse prosecution, holding that the trial judge abused her discretion by allowing prior bad act testimony covering forty-two transcript pages to overwhelm the twenty-six pages of testimony on the charged conduct. The court stressed that trial judges have an independent duty to control the volume of prior bad act evidence and that limiting instructions cannot cure the prejudice when such evidence is so voluminous as to invite a propensity inference in a credibility-dependent case.
The Nevada Supreme Court reversed Allen’s convictions for sexual assault on a minor, holding en banc that a district court abused its discretion in finding A.S.’s juvenile records of a nearly identical prior sexual offense irrelevant to Allen’s alternative-suspect defense. The court found the error was not harmless where it foreclosed pretrial investigation, terminated the admissibility inquiry, the jury independently indicated interest in the alternative suspect, and the State exploited the exclusion to elicit misleading testimony.
The Massachusetts Appeals Court vacated a sexually dangerous person (SDP) civil commitment after finding that all three Commonwealth experts had based their sexual sadism disorder diagnoses almost entirely on facts from police reports for charges dismissed in 2002 and 2003. Because the petitioner requested a voir dire on independent admissibility and the Commonwealth never showed the complainants could or would testify, allowing the experts to rely on those allegations without an admissibility hearing was reversible error under Markvart and Department of Youth Servs. v. A Juvenile.
The Massachusetts Appeals Court vacated Robert Albert’s rape-of-a-child convictions and remanded for a new trial, holding that his daughter’s private diary entry — written the day after the last alleged assault but never shared with anyone — could not qualify as “first complaint evidence” under Commonwealth v. King because the first complaint doctrine requires a communication to another person; the entry was more detailed than the actual oral disclosure, deprived the defendant of a witness to cross-examine, and was accompanied by a limiting instruction that misdescribed the diary as a “telling” of the assault.
The North Carolina Court of Appeals arrested judgment on an assault-inflicting-serious-bodily-injury conviction as merging with AWDWIKISI under the double jeopardy clause when no distinct interruption in the assault was established, while affirming that a prosecutor’s one-minute breath-holding demonstration during closing argument was not grossly improper and that a lesser-included offense instruction on assault inflicting serious injury was not required where the State’s evidence of deadly-weapon use was uncontradicted.
The Utah Court of Appeals affirmed six sexual-abuse convictions, holding that uncharged grooming conduct is admissible as intrinsic evidence outside Rule 404(b), that a charging variance between the information and the acts proven at trial raises sufficiency and notice issues—not jurisdictional ones—and that failure to seek a trial continuance upon discovering the variance waives procedural-due-process claims.