Court Filings

The Illinois Appellate Court affirmed defendant Kevin Lanigan’s conviction for aggravated driving under the influence. After a bench trial based on testimony from the arresting officer and body-worn camera footage, the trial court found Lanigan guilty of being in actual physical control of a vehicle while under the influence and while his driving privileges were suspended. The appellate court held the camera footage was properly admitted and that the combined evidence—Lanigan asleep at the wheel with the car running, the smell of alcohol, his admission of four drinks, field sobriety test performance, and refusal of breath testing—was sufficient to prove impairment beyond a reasonable doubt.

The Sixth District Court of Appeal affirmed the circuit court's judgment in the criminal case of Terrelle A. Tullis. The appeal was taken pursuant to Florida Rule of Appellate Procedure 9.141(b)(2). The court concluded that a life sentence is clear and definite in meaning and upheld the sentencing outcome, relying on Ratliff v. State to support that the Legislature intends a life sentence to keep a defendant in prison for the remainder of life.

The Sixth District Court of Appeal affirmed the circuit court's decision in the criminal case of Lace Melitta Heflin. The appeal was considered under Florida Rule of Appellate Procedure 9.141(b)(2). The court relied on Ratliff v. State to conclude that a statutory life sentence is sufficiently definite and means the defendant is intended to remain in prison for the rest of her life, so no error warranted reversal.

The Sixth District Court of Appeal affirmed the trial court's decision in appellant Edgar E. Oliver's appeal from a Collier County circuit court order. The panel, writing per curiam, held that a statutory sentence of life imprisonment is intended by the Legislature to keep a defendant in prison for the remainder of his life, citing Ratliff v. State. No further factual discussion or modification of the sentence was provided; the appeal was disposed of by a short opinion affirming the lower court.

The Ohio Supreme Court affirmed the court of appeals’ decision that sufficient evidence supported a juvenile delinquency adjudication for rape. A 14-year-old (Paul) was adjudicated for one count of rape for engaging in anal intercourse with a 15-year-old resident (Charles) at a youth home. Witness testimony described Paul holding Charles by the waist and thrusting while Charles said he did not want to comply and tried to get Paul to stop. The court applied the same sufficiency standard used in adult criminal cases and concluded a rational factfinder could find Paul used force to compel submission.

The Florida Second District Court of Appeal affirmed the lower court's ruling in an appeal brought by Lary Scott Morris against the State of Florida. The appellate panel issued a brief per curiam decision—without published opinion—concluding that the trial court's decision was correct and required no change. All three judges concurred, and the opinion is subject to revision before official publication. No additional reasoning or factual background was provided in the court's short order.

The Second District Court of Appeal affirmed the circuit court's summary denial of a postconviction motion by Angel Gabriel Mejia. Mejia argued that a single sentence in his pro se 3.850 motion raised an involuntary-plea claim based on counsel's alleged failure to advise him about a 25-year mandatory minimum. The appellate court held that the motion did not fairly present that distinct claim and, in any event, the plea colloquy and corrected plea form conclusively refuted the allegation because Mejia was expressly advised of the mandatory minimums and acknowledged understanding them in open court.

The Second District Court of Appeal affirmed Craig Edward Leeks' convictions and sentences for second-degree murder and improper exhibition of a firearm. Leeks argued the trial court erred by not entering a written competency order and by not conducting a full competency hearing. The appellate court found the trial judge made adequate oral findings of competency, relied on a prior psychological evaluation, repeatedly questioned Leeks during the proceedings, and observed no lapse in competency. Because Leeks did not raise the omission below and has not shown fundamental error, the failure to reduce the competency finding to a written order did not require reversal.

The Second District Court of Appeal reviewed Kyle Kemp's appeal from the Pinellas County Circuit Court under Florida Rule of Appellate Procedure 9.141(b)(2). After consideration, the panel issued a per curiam decision affirming the lower court's judgment. The opinion is concise, lists the judges who concurred, and notes it may be revised before official publication. No reasoning or factual discussion is included in the published entry beyond the affirmance.

The Florida Second District Court of Appeal affirmed the lower court's decision in the criminal matter of Scott Warren Cullen v. State of Florida. The appeal challenged an order from the Circuit Court for Sarasota County, but the appellate court, in a per curiam decision, unanimously affirmed the judgment below. No extended opinion or separate written reasoning was provided in the published entry; the court's brief ruling concludes the appeal lacks merit and upholds the trial-court outcome.

The Court of Appeals affirmed the trial court’s sentencing of Zachary Boyce. The court held that the 2023 amendment to RCW 9.94A.525, which generally prevents counting most juvenile felony adjudications in an offender score, does not apply retroactively because the legislature did not clearly express that intent. Under Washington law and the savings clause (RCW 10.01.040) and RCW 9.94A.345, defendants must be sentenced according to the law in effect when the offense was committed unless the legislature expressly provides otherwise. Because no clear retroactivity language appeared in the amendment, Boyce’s juvenile adjudications were properly counted.

The Georgia Court of Appeals affirmed Flint Duerfeldt’s convictions for child molestation, aggravated sexual battery, and aggravated child molestation and upheld the trial court’s denial of his motion for new trial. Duerfeldt argued the admission of a forensic interviewer’s testimony that the victim’s disclosure was consistent with other sexually abused children violated the amended expert-evidence rule and that trial counsel was ineffective for not objecting. The court found the testimony was properly admissible under OCGA § 24-7-702, did not impermissibly vouch for credibility, and counsel’s failure to object was not deficient because an objection would have been futile.

The Georgia Court of Appeals affirmed the trial court’s denial of Edward Ball’s pretrial motion to suppress evidence seized from his home after a jury convicted him of multiple drug and firearm offenses. The court held the search warrant was supported by probable cause based on controlled buys, surveillance tying Ball and a vehicle registered to him to drug transactions, and the officer’s training and experience; it also found no reversible error in alleged reliance on evidence outside the affidavit. Challenges that the warrant was overbroad or lacked particularity failed because Ball did not show any harm or preserve a detailed argument below.

The Ohio Court of Appeals (Eighth District) affirmed David Spivey’s convictions for two counts of murder and related felonious-assault and firearm specifications arising from the July 30, 2020 killings of brothers Dominique and Delvont’e King. After a second jury trial, Spivey was convicted and sentenced to 15 years to life plus six years of consecutive firearm time (parole eligibility after 21 years). On appeal he challenged multiple evidentiary rulings, the weight of the evidence, juror bias, and claims of ineffective assistance of trial counsel. The court rejected each argument, finding no plain error or prejudice and concluding counsel’s performance was not deficient.

The Ohio Eighth District Court of Appeals affirmed De’Ane Peterson’s convictions and 120-month aggregate prison sentence after he pleaded guilty in three Cuyahoga County cases (2023, 2024, 2025). The court found the trial judge complied with Crim.R. 11 and that Peterson’s guilty pleas were knowing, intelligent, and voluntary. The court rejected claims of ineffective assistance of counsel because Peterson did not show his plea was caused by counsel’s conduct. The court also found the record supported the trial court’s consecutive-sentencing findings under R.C. 2929.14(C)(4).

The Ohio Court of Appeals for Cuyahoga County affirmed the trial court’s denial of Airik Kahlead Jordan’s presentence motion to withdraw his guilty pleas. Jordan had pleaded guilty as part of a plea agreement to involuntary manslaughter, kidnapping, and related firearm and weapon counts with an agreed sentence range; he later filed a pro se motion saying he pleaded out of fear and maintained his innocence. The appellate court held the trial court did not abuse its discretion because Jordan’s plea colloquy was thorough, he knowingly and voluntarily pleaded guilty, and his motion amounted to a mere change of heart unsupported by new evidence.

The Ohio Eighth District Court of Appeals affirmed Nathan Jones’s convictions and related firearm specifications following a bench trial. Jones was convicted of multiple sexual and related offenses after a victim testified he abducted and assaulted her at gunpoint, and DNA and other evidence linked him to the crimes. Jones argued the firearm specifications tied to three sexual-offense counts lacked sufficient evidence and were against the manifest weight of the evidence because the gun was only mentioned at the victim’s home and not at the later assault location. The court found reasonable inferences supported the specifications and upheld the convictions.

The Ohio Eighth District Court of Appeals affirmed William Greene’s convictions after a jury found him guilty of two counts of gross sexual imposition and two counts of disseminating matter harmful to juveniles. Greene challenged admission of forensic interview statements, sufficiency of evidence, and manifest weight of the evidence. The court held the forensic interview testimony was admissible under the medical-diagnosis exception and not barred by the confrontation rule because the children testified. The court found ample evidence that Greene engaged in masturbatory conduct and showed pornography in shared living areas while the victims were minors, supporting the convictions and sentence of 36 months.

The Ohio Court of Appeals affirmed Kevin Burge’s convictions, sentence, and the trial court’s denial of his post-sentence motion to withdraw guilty pleas. Burge pleaded guilty to 39 counts from a 63-count indictment after a thorough plea colloquy that the court found complied with Criminal Rule 11. The court rejected claims of ineffective assistance, involuntary plea, improper consecutive sentencing, and that a hearing was required on his post-sentence motion. The appellate court concluded the record showed Burge understood the plea consequences, the trial court made the required sentencing findings, and no manifest injustice was shown.

The court affirmed the trial court’s denial of Raliegh Abraham’s untimely motion for a new trial and remanded the case for the trial court to consider Abraham’s pending motion for leave. Abraham had been convicted after a bench trial and sentenced; his direct appeal and application to reopen were denied. He filed a motion for leave and, on the same day, filed an untimely motion for new trial based on newly discovered evidence. Because he did not obtain leave before filing the untimely motion as required by Crim.R. 33(B), the appellate court affirmed the denial and instructed the trial court to rule on the motion for leave.

The Ohio Fifth District Court of Appeals affirmed the Tuscarawas County Common Pleas Court's judgment after Lee Stiffler pleaded no contest to failure to comply with a police officer and resisting arrest and received two years of community control. Stiffler challenged the trial court's denial of his motion to suppress, arguing the officer could read his temporary tag, the tag was in plain view, he did not drive onto a curb, and his agitation did not justify further detention. The appellate court found the trial court's factual findings credible, held that the officer reasonably detained Stiffler to check license/registration/insurance under governing precedents, and determined there was reasonable suspicion to detain for sobriety testing.

The Ohio Fifth District Court of Appeals affirmed the trial court's dismissal of Robert Phelps' petition for post-conviction relief as untimely. Phelps had pleaded guilty in 2020 and was sentenced pursuant to a negotiated 15-year term; his direct-appeal transcript was filed June 8, 2021. He filed the post-conviction petition on September 4, 2025, beyond the 365-day statutory deadline. The court held the petition did not meet the narrow statutory exceptions allowing consideration of untimely petitions, and therefore the trial court correctly dismissed without findings or an evidentiary hearing.

The Ohio Court of Appeals affirmed the Franklin County trial court’s denial of Robert Lindsey’s amended petition for postconviction relief. Lindsey had been convicted of murder for stabbing his mother; he argued trial counsel was ineffective for failing to investigate potential prior abuse more fully, not consulting a domestic-violence expert, and failing to seek a no‑duty‑to‑retreat jury instruction. The appellate court found counsel’s investigation and strategic choices reasonable based on the record and Lindsey’s own statements, and held that even if some investigation was lacking, there was no reasonable probability the outcome would have changed.

The Pennsylvania Supreme Court affirmed the Superior Court and upheld the trial court’s denial of the Commonwealth’s motion to nolle prosequi charges of negligent simple assault against former officer Stuart Harrison. The Commonwealth argued its key eyewitness had died and, without that testimony, it could not prove criminal negligence beyond a reasonable doubt. The Court held the trial court applied the correct Reinhart standard — evaluating whether the Commonwealth’s stated reasons were valid and reasonable — and found other available witnesses provided sufficient evidence to allow trial, so the nolle prosequi was not justified.

Justice Dougherty concurred in part and dissented in part from the Court’s decision affirming the Superior Court’s judgment in Commonwealth v. Harrison. He would have reversed the Superior Court’s published opinion and remanded for application of this Court’s binding precedent (particularly Commonwealth v. Reinhart and Commonwealth v. DiPasquale) governing judicial review of a prosecutor’s motion to nolle prosequi. He criticizes the Superior Court for adopting a de novo standard for review and the majority for affirming on an alternate ground and addressing issues the Commonwealth did not raise, while warning about separation-of-powers concerns and unresolved practical consequences of the decision.

The Appellate Division, First Department, affirmed the conviction and sentence of Stephanie Rodriguez. Rodriguez appealed a June 22, 2022 judgment of the Supreme Court, Bronx County. After oral argument and consideration, the appellate court found the sentence was not excessive and therefore upheld the trial court's judgment. The opinion is a brief affirmance without extended written opinion and refers defense counsel to the court's procedural rule § 606.5.

The Appellate Division, First Department affirmed defendant Luis Mendez’s convictions for attempted criminal possession of a weapon in the second degree and third-degree burglary and his concurrent sentences. The court held Mendez validly waived his right to appeal, which bars review of his suppression challenge, and alternatively found the trial court correctly denied suppression. The court accepted credibility findings and concluded police lawfully approached based on an intelligence report about a trend of firearms in fanny packs, observed a street-crossing violation, and legitimately pursued Mendez when he fled, making the abandonment of the fanny pack and the discovery of the gun lawful.

The Appellate Division, First Department affirmed defendant Michael T. Jackson's conviction and sentence after a guilty plea for criminal possession of a firearm, rejecting his challenges. The court held Jackson validly waived his right to appeal, which bars review of his excessive-sentence and most probation-condition claims. A facial challenge to the statute's "good moral character" licensing provision survives waiver and Jackson has standing, but the claim was unpreserved and not reviewed in the interest of justice; alternatively the court found it meritless. Ineffective-assistance claims based on counsel's failure to raise that argument must be pursued in a CPL 440.10 motion and were otherwise rejected on the record.

The Appellate Division, First Department affirmed the Bronx County Supreme Court judgment entered December 17, 2024, in the criminal case against Joshua Brooks. The appeal challenged the sentence, but the appellate court, after argument and deliberation, found the sentence not excessive and affirmed. The decision is brief and focuses solely on the review of the sentence; no change to the conviction or sentence was ordered. Counsel for the appellant was referred to the court's Rule 606.5.

The Court of Appeals affirmed Reynaldo Antonio Sanchez’s conviction and 40-year sentence for continuous sexual abuse of a young child. Sanchez argued he was denied a speedy trial and that the trial court erred by admitting portions of a medical examiner’s report and testimony that relied on a Spanish-to-English translation. The court held Sanchez failed to preserve the speedy-trial claim because he never made an unambiguous, timely demand in the trial court. The court also upheld admission of the translated statements, finding the translator acted as a reliable language conduit and that the statements were non-testimonial for confrontation-clause purposes.