Joseph Minor was convicted after a jury trial of first-degree murder while armed of Gregory Lee and related firearm offenses, based primarily on testimony from an eyewitness who knew Minor and identified him as one of the shooters during an alley argument that turned deadly. Minor appealed his convictions and the denial of his D.C. Code § 23-110 motion for a new trial, arguing that the trial court should have excluded certain statements by the victim as hearsay, that a jury instruction on aiding and abetting was improper, and that his trial counsel was ineffective for failing to investigate or call an expert on eyewitness identification. The D.C. Court of Appeals affirmed the convictions and the denial of the new-trial motion. It held that Minor had not shown plain error on the direct-appeal claims and had failed to prove deficient performance by counsel under Strickland, because his supporting affidavit was inadmissible hearsay, the eyewitness’s long familiarity with Minor reduced the relevance of stranger-identification research, and counsel could reasonably have chosen other defense strategies.

criminal law

In Caesar v. United States, Diandre Caesar appealed his convictions for two counts of assault with a deadly weapon and two counts of possession of a firearm during a crime of violence, arising from a June 2022 shooting that followed a dispute over a milkcrate blocking a McDonald’s exit lane in Northeast D.C., in which the victims heard gunshots striking their car as they drove away. Caesar challenged the trial court’s denial of his motion to suppress an out-of-court photo identification and in-court identification as unduly suggestive, its refusal to order production of witness names from a later unrelated shooting that he claimed could support a third-party perpetrator defense under Winfield, the sufficiency of the evidence for intent-to-frighten assault where the victims did not see the gun, and aspects of his sentencing. The District of Columbia Court of Appeals affirmed the convictions and sentence, holding that the identifications were reliable under the totality of the circumstances, that the requested discovery was too attenuated and speculative to meet Brady or Winfield standards, and that the evidence was sufficient to support the jury’s findings, while remanding solely to vacate one merged PFCV conviction.

criminal lawguns

In Caesar v. United States, Diandre Caesar appealed his convictions for two counts of assault with a deadly weapon and two counts of possession of a firearm during a crime of violence, arising from a June 2022 shooting that followed a dispute over a milkcrate blocking a McDonald’s exit lane in Northeast D.C., in which the victims heard gunshots striking their car as they drove away. Caesar challenged the trial court’s denial of his motion to suppress an out-of-court photo identification and in-court identification as unduly suggestive, its refusal to order production of witness names from a later unrelated shooting that he claimed could support a third-party perpetrator defense under Winfield, the sufficiency of the evidence for intent-to-frighten assault where the victims did not see the gun, and aspects of his sentencing. The District of Columbia Court of Appeals affirmed the convictions and sentence, holding that the identifications were reliable under the totality of the circumstances, that the requested discovery was too attenuated and speculative to meet Brady or Winfield standards, and that the evidence was sufficient to support the jury’s findings, while remanding solely to vacate one merged PFCV conviction.

criminal lawguns