Recent State Court Rulings in Criminal Law
Once the United States Supreme Court rules on an issue of Constitutional law, that decision is binding on all state courts and lower federal courts.
However, minor distinctions from case to case mean that state and federal district courts are often called upon to make decisions about issues that are closely related, but haven’t directly been decided by the United States Supreme Court.
In those cases, courts are not bound by the rulings of other jurisdictions, but may use those decisions and the reasoning set forth in them to reach their own decisions.
Therefore, it’s important to be aware of relevant criminal defense decisions, even if they’re from another jurisdiction. They may provide the persuasive authority that supports your argument-or you may need to be prepared to counter them.
Colorado Supreme Court Overturns Sentence For Crime Different From Jury Verdict
The Colorado Supreme Court recently overturned a judge’s sentence for a class 4 felony following a jury’s guilty verdict for only a class 5 felony. Medina v. People, 06SC188 (Colo. S.Ct. July 2, 2007). Juanita Medina was convicted of the class 5 felony of being an accessory to a crime, carrying a sentencing range of one to three years imprisonment. C.R.S. 18-1.3-401 (2006). She was sentenced, as a class 4 felony, to six years imprisonment. Id.
Under Colorado statutes, the elements of the class 4 offense of accessory requires that the defendant know that the person whom she assisted had, in fact, committed a serious felony. Medina. C.R.S. 18-8-105(3). The class 5 offense only requires the defendant to have known that the person whom she assisted was suspected of committing a serious felony. Id. C.R.S. 18-8-105(4).
The information charging Medina merely stated that she rendered assistance to Derek Lee Martinez, who was wanted for first and second degree murder. The information failed to accuse Medina of knowing that Martinez had, in fact, committed the crime. This confusion was cleared up when the prosecution proffered jury instructions asked the jury to return a guilty verdict if Medina rendered assistance to Martinez, who was “suspected of and wanted for a crime.” Id. Neither party argued, during the trial, that Medina knew Martinez had actually committed the murder. The prosecution said, in its closing argument, that “[t]here is no dispute . . . that [Medina] knowingly rendered assistance to him, an individual who was suspected of and wanted for a crime.” Id. (emphasis original in Colo. S.Ct. opinion). The jury returned a verdict of guilty to class 5 felony accessory. Neither party objected.
Later, a different judge presided over her sentencing. The judge said the case was before him “on the Defendant’s conviction of being an accessory to a crime which was murder, a Class 1 and Class 2 felony; and her offense is classified as a Class 4 felony.” Id. The judge then sentenced her to the maximum for a class 4 felony, 6 years in prison. She did not object.
Medina appealed, asking that her conviction be vacated and the case returned for sentencing as a class 5 felony. The appellate court, amazingly, upheld her sentence, saying that “[t]here was no dispute that defendant knew Martinez had committed first or second degree murder.” Id.
The Colorado Supreme Court determined that Medina was sentenced in violation of her Fifth Amendment Due Process right to proof beyond a reasonable doubt of every fact necessary to constitute the crime with which a defendant is charged, and her Sixth Amendment right to a trial by jury. Under Apprendi, only a jury may decide facts which could increase a defendant’s sentence beyond the given range for a particular crime. 530 U.S. 466 (2000). Medina was sentenced based on her knowledge that Martinez had, in fact, committed murder, while the jury convicted her of no more than knowing Martinez was suspected of committing murder. The judge’s determination that she knew of the fact of Martinez’s crime took her sentence from a maximum of three years to a maximum of six, to which she was sentenced, in violation of Apprendi. Her conviction of class 5 felony accessory was upheld, however. Her sentenced for class 4 accessory was vacated and the case was returned for sentencing based on her actual conviction.