Commonwealth v. Jackson — Loaded-firearm offense requires knowledge
The Massachusetts Appeals Court held that carrying a loaded firearm while intoxicated requires proof the defendant knew the weapon was loaded.
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Statutory Interpretation
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Luna v. State — Children on another floor were physically present
The Indiana Court of Appeals held that children on other floors were physically present for felony domestic battery because they might hear the attack and the defendant knew it.
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Armstrong v. State — Nevada upholds machine-gun ban but vacates overlapping firearm conviction
The Nevada Supreme Court upheld state bans on machine guns and auto-sear-equipped firearms but reversed a duplicative modified-firearm conviction under double-jeopardy principles.
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Commonwealth v. Goncalves — SJC requires a third-party recipient for image dissemination
The Massachusetts SJC held that sending a secretly taken intimate image only to the person depicted is not dissemination under General Laws chapter 272, section 105(c).
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McDaniel v. State — Nevada clarifies graduated sanctions for probation violations
The Nevada Supreme Court held that the graduated-sanctions statutes apply to sentences imposed after July 1, 2020, while allowing courts to consider earlier nontechnical violations when later technical violations occur.
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Krasner v. Sunday — Supreme Court upholds SEPTA special-prosecutor law
The Pennsylvania Supreme Court rejected Philadelphia District Attorney Larry Krasner’s constitutional challenge to Act 40’s SEPTA special-prosecutor regime.
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Commonwealth v. Worzel — DUI court retains discretion after an ARD violation
The Pennsylvania Supreme Court held that a DUI defendant’s violation of an ARD condition does not automatically require termination from the diversion program.
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Commonwealth v. Gaspard — Theft-by-deception conviction requires proof the lie changed benefits
The Pennsylvania Supreme Court vacated a theft-by-deception conviction because prosecutors never proved that omitted business information affected the defendant’s Section 8 benefits.
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Alexander v. State — Misdemeanor contributing charge does not require knowledge of age
A divided Indiana Court of Appeals held that misdemeanor contributing to delinquency does not require proof that the defendant knew the recipients of alcohol were under eighteen.
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Hre v. State — Rental-Car Costs Excluded from Restitution
The Indiana Court of Appeals held that the criminal restitution statute does not authorize reimbursement for a victim’s rental-car expenses.
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ACLU v. Wilson — Public execution-team information falls outside secrecy law
The South Carolina Supreme Court held that the execution-secrecy statute does not cover public or nonconfidential identifying information and does not punish its later repetition.
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Commonwealth v. Pollard — Superior Court reinstates SORNA charges tied to 1990 conviction
The Superior Court held that SORNA II’s nonpunitive Subchapter I requires registration by an offender who began lifetime registration under Megan’s Law II, even though his offense predated Pennsylvania’s registration statutes.
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Commonwealth v. Green — Commonwealth Court defines provocation under Pennsylvania’s dangerous-dog law
The Commonwealth Court held that a dog attack is without provocation when, under all surrounding circumstances, the victim could not reasonably foresee that her conduct would trigger the attack.
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Deamicis v. State — One threatening act supports an assault count for each victim
The Nevada Supreme Court held that NRS 200.471 permits a separate assault conviction for every person intentionally placed in reasonable fear of immediate bodily harm.
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State v. Tamoua — Court excludes compulsion from murder special mitigation
The Utah Supreme Court held that compulsion is an excuse, not a legal justification, and therefore cannot support the murder statute’s special-mitigation defense.
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Todd v. State — Wyoming Supreme Court Clarifies Child-Exploitation Attempt
The Wyoming Supreme Court held that asking a child to touch an adult’s exposed genitals can support attempted sexual exploitation under the statute’s masturbation category.
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Commonwealth v. Wilson — Supreme Court limits overdose-response immunity after an independent inventory search
The Pennsylvania Supreme Court held that an inventory search conducted after an overdose victim entered paramedics’ care was independent of the emergency call and fell outside statutory medical-amnesty protection.
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Williams — Castle doctrine can protect a lawful vehicle occupant after he exits
The Supreme Court modified and affirmed. Under the facts and statutory text, Williams remained a lawful occupant for purposes of N.C.G.S. § 14-51.2 even after exiting the vehicle during the confrontation. He was entitled to the presumption instruction, and the failure to give it was prejudicial.
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Commonwealth v. Felder — Superior Court narrows risking-catastrophe liability for reckless driving
The Superior Court discharged a risking-catastrophe conviction because reckless driving did not create the extraordinary, widespread danger the statute requires, while affirming evading arrest on foot.
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State v. Vance — Retaining stolen property is a continuing offense
The Utah Court of Appeals held that retaining stolen property can continue until possession ends, making the prosecution of a stolen skid steer timely.
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In re J.M. — Prosecutor may challenge an improperly offered juvenile diversion
A divided Utah Supreme Court held that a prosecutor may file a delinquency petition after an ineligible minor received a nonjudicial adjustment from probation.
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In the Interest of RCR — Wyoming Boys’ School Cannot Hold Alleged Delinquents Before Adjudication
The Wyoming Supreme Court reversed a contempt order against the Wyoming Boys’ School for refusing to admit an alleged delinquent juvenile before adjudication. The court held that Wyoming law expressly prohibits pre-adjudication placement at WBS, which is a reformatory for adjudicated delinquents — not a juvenile detention facility — and that the juvenile court abused its discretion by ordering such placement. All three exceptions to the mootness doctrine applied, allowing the court to reach the merits despite the case having been resolved below.
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POM of Pennsylvania v. Department of Revenue — Pennsylvania Supreme Court Holds Skill Game Devices Are Slot Machines Requiring Gaming Act Licensing
The Pennsylvania Supreme Court reversed the Commonwealth Court and held that “skill game” devices—electronic gaming terminals marketed as legal skill-based alternatives to slot machines—are “slot machines” under the Gaming Act and prohibited “gambling devices” under the Crimes Code, with a 120-day stay giving operators time to adjust before enforcement resumes.