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Articles by Douglas Ankney

Maryland Court of Appeals Abrogates Rule Requiring Corroboration of Accomplices’ Testimony and Announces New Rule

by Douglas Ankney

The Maryland Court of Appeals abrogated the rule that required the testimony of accomplice(s) be independently corroborated and replaced it with a new rule.

In August 2015, Sandeep Bhulai’s body was discovered lying next to his vehicle. He had been shot multiple times. The investigation led police ...

9th Circuit: Sentence Under 18 U.S.C. § 3583(k) Violated Ex Post Facto Clause When Underlying Offense Was Committed in 2005

by Douglas Ankney

The U.S. Court of Appeals for the Ninth Circuit held that a sentence under 18 U.S.C. § 3583(k) for revocation of a term of supervised release that was imposed as a result of crimes that occurred in 2005 violated the Ex Post Facto Clause.

In 2007, Tommy ...

California Supreme Court: Where Electronics Search Condition of Probation Is Not Reasonably Related to Future Criminality, Condition Is Invalid

by Douglas Ankney

The Supreme Court of California held that where an electronics search condition of probation is not reasonably related to future criminality the condition is invalid under People v. Lent, 541 P.2d 545 (Cal. 1975).

In 2014, the juvenile defendant (identified as “Ricardo”) was declared a ward of ...

Second Circuit: Federal Habeas Relief Warranted Where State Trial Court’s Evidentiary Rulings Deprived Defendant of Right to Present a Complete Defense

by Douglas Ankney

The U.S. Court of Appeals for the Second Circuit instructed a district court to issue a conditional writ of habeas corpus based on a state court’s erroneous application of evidentiary rules that resulted in the denial of the defendant’s right to present a complete defense.

Paul Scrimo ...

10th Circuit: Child Porn Stored on Multiple Devices Constitutes One Count of Possession Under 18 U.S.C. § 2252A(a)(5)(B)

by Douglas Ankney

The U.S. Court of Appeals for the Tenth Circuit held that child pornography stored on multiple devices at the same location and at the same time is only one count of possession under 18 U.S.C. § 2252A(a)(5)(B).

Samuel Elliott had over 8,000 images of child pornography, including ...

Second Circuit Clarifies Conditions for Releasing a Defendant on Bail to Home Detention With Private Armed Security Guards

by Douglas Ankney

The U.S. Court of Appeals for the Second Circuit clarified the circumstances when a defendant’s bail may include home confinement coupled with private armed security guards.

Jean Boustani applied for bail pending trial, proposing conditions that included home confinement under supervision of private security guards paid for ...

Massachusetts Supreme Court Suppresses Evidence Obtained Following Illegally Prolonged Traffic Stop, Orders New Trial

by Douglas Ankney

The Supreme Judicial Court vacated the convictions of Paulos Tavares, ruling that the trial court failed to suppress evidence that was obtained as the result of an officer extending a vehicle stop without probable cause, which made the evidence the proverbial fruit of the poisonous tree.

John ...

Kansas Supreme Court: Expired License Plate Doesn’t Attenuate Evidence from Illegal Seizure

by Douglas Ankney

The Supreme Court of Kansas ruled that an officer’s discovery of an expired license plate subsequent to an illegal seizure did not attenuate the evidence obtained as a result of the illegal seizure. 

Daniel Christian lawfully parked his car on a public street and sat there ...

Ninth Circuit Clarifies When Warrantless Searches of Cellphones at Border Are Reasonable

by Douglas Ankney

The U.S. Court of Appeals for the Ninth Circuit has clarified when warrantless searches of cellphones at the border are reasonable.

Customs and Border Patrol (“CBP”) agents discovered nearly 31 pounds of cocaine in the spare tire of Miguel Angel Cano’s vehicle as he attempted to enter ...

California Court of Appeal Announces Defendant Convicted of Felony Accessory Is Eligible for Resentencing Under Proposition 64

by Douglas Ankney

In a case of first impression, the California Court of Appeal for Division One of the First District announced that a person convicted of felony accessory is eligible for resentencing under Proposition 64. 

In September 2013, William Roy Boatwright was arrested while exiting a house later ...



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