# Criminal Defense Resources™

> Plain-English court rulings and resources for families of pro per/pro se criminal defendants. Free, plain-English summaries of real criminal court rulings (U.S. Supreme Court, federal appeals courts, and state courts; nationwide), each linked to the full opinion. General educational information, not legal advice. Not a law firm.

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## Rulings
- [Chatrie v. United States, No. 25-112 (U.S. June 29, 2026)](https://criminaldefenseresources.com/rulings/chatrie-v-united-states/): The Court held that police conducted a Fourth Amendment search when they obtained a person's Google Location History data through a geofence warrant, because people have a reasonable expectation of privacy in their cell-phone location information. The Court did not decide whether this particular multi-step warrant was valid; it vacated the Fourth Circuit's decision and sent the case back for that court to decide.
- [United States v. Chatrie, 136 F.4th 100 (4th Cir. 2025) (en banc)](https://criminaldefenseresources.com/rulings/united-states-v-chatrie-en-banc/): The full Fourth Circuit affirmed the conviction in a one-sentence unsigned opinion. The judges were evenly divided on whether obtaining the geofence data was a Fourth Amendment search. The U.S. Supreme Court later vacated this decision in Chatrie v. United States (2026).
- [United States v. Smith, 110 F.4th 817 (5th Cir. 2024)](https://criminaldefenseresources.com/rulings/united-states-v-smith-5th-cir/): The Fifth Circuit held that geofence warrants are modern-day general warrants that violate the Fourth Amendment. But it did not suppress the evidence in that case, because officers relied in good faith on the warrant.
- [United States v. Chatrie, 107 F.4th 319 (4th Cir. 2024)](https://criminaldefenseresources.com/rulings/united-states-v-chatrie-panel/): A divided Fourth Circuit panel held that no search occurred because the defendant did not have a reasonable expectation of privacy in two hours of Location History data he had voluntarily shared with Google. The full court later reheard the case.
- [Erlinger v. United States, 602 U.S. 821 (2024)](https://criminaldefenseresources.com/rulings/erlinger-v-united-states/): The Court held that, under the federal Armed Career Criminal Act, whether a defendant's past offenses happened on separate "occasions" must be decided by a unanimous jury beyond a reasonable doubt (or admitted by the defendant), not decided by a judge.
- [Vega v. Tekoh, 597 U.S. 134 (2022)](https://criminaldefenseresources.com/rulings/vega-v-tekoh/): The Court held that a violation of the Miranda rules, by itself, does not give a person the right to sue an officer for money damages under the federal civil rights law (42 U.S.C. section 1983).
- [State v. Mixton, 250 Ariz. 282 (2021)](https://criminaldefenseresources.com/rulings/state-v-mixton/): The Arizona Supreme Court held that neither the Fourth Amendment nor the Arizona Constitution's private affairs clause requires a warrant for police to obtain a person's IP address or internet subscriber information from a service provider.
- [State v. Soto-Fong, 250 Ariz. 1 (2020)](https://criminaldefenseresources.com/rulings/state-v-soto-fong/): The Arizona Supreme Court held that consecutive prison sentences for multiple crimes committed as a juvenile do not violate the Eighth Amendment, even when the total exceeds the person's life expectancy, because the U.S. Supreme Court's juvenile-sentencing cases address sentences for single crimes.
- [United States v. Cano, 934 F.3d 1002 (9th Cir. 2019)](https://criminaldefenseresources.com/rulings/united-states-v-cano/): The Ninth Circuit held that at the border, officers may do a manual search of a cell phone without suspicion, but a forensic (device-copying) search requires reasonable suspicion. It also held that border phone searches are limited to looking for digital contraband.
- [Garza v. Idaho, 586 U.S. 232 (2019)](https://criminaldefenseresources.com/rulings/garza-v-idaho/): The Court held that when a lawyer ignores a defendant's instruction to file a notice of appeal, harm is presumed, even if the defendant signed a plea agreement that waived some appeal rights.
- [Carpenter v. United States, 585 U.S. 296 (2018)](https://criminaldefenseresources.com/rulings/carpenter-v-united-states/): The Court held that when the government obtains a person's historical cell-site location records from a phone company, that is a Fourth Amendment search, and police generally need a warrant.
- [McCoy v. Louisiana, 584 U.S. 414 (2018)](https://criminaldefenseresources.com/rulings/mccoy-v-louisiana/): The Court held that a defendant has the right to insist that his lawyer not admit guilt at trial, even when the lawyer believes admitting guilt is the best way to avoid a death sentence. Violating that choice is a "structural" error that requires a new trial without any separate showing of harm.
- [Simpson v. Miller, 241 Ariz. 341 (2017)](https://criminaldefenseresources.com/rulings/simpson-v-miller/): The Arizona Supreme Court held that Arizona's rule denying bail to everyone charged with sexual conduct with a minor under 15, when the proof is evident or presumption great, violated due process because it did not require an individualized finding that the person is dangerous.
- [State v. Peoples, 240 Ariz. 244 (2016)](https://criminaldefenseresources.com/rulings/state-v-peoples/): The Arizona Supreme Court held that a person has a reasonable expectation of privacy in the contents of his cell phone, even when the phone is left in someone else's home, and that a warrantless search of the phone violated the Fourth Amendment.
- [United States v. Lambis, 197 F. Supp. 3d 606 (S.D.N.Y. 2016)](https://criminaldefenseresources.com/rulings/united-states-v-lambis/): A federal trial court in New York held that agents' use of a cell-site simulator, without a warrant, to find a phone inside a specific apartment was an unconstitutional search, and it suppressed the evidence found as a result.
- [Lynch v. Arizona, 578 U.S. 613 (2016)](https://criminaldefenseresources.com/rulings/lynch-v-arizona/): In a short unsigned opinion, the Court held that when a capital defendant's future dangerousness is at issue and the only alternative to death is life without parole, the defendant is entitled to tell the jury he would not be eligible for parole. The possibility of future clemency or law changes does not remove that right.
- [United States v. Graham, 824 F.3d 421 (4th Cir. 2016) (en banc)](https://criminaldefenseresources.com/rulings/united-states-v-graham/): The full Fourth Circuit held that the government's acquisition of historical cell-site records from a phone company was not a Fourth Amendment search, applying the third-party doctrine.
- [State v. Valenzuela, 239 Ariz. 299 (2016)](https://criminaldefenseresources.com/rulings/state-v-valenzuela/): The Arizona Supreme Court held that a DUI arrestee's consent to a blood or breath test is not voluntary under the Fourth Amendment when it follows an officer's statement that Arizona law requires the person to submit. In this case, the evidence was not suppressed because officers had relied in good faith on court decisions in effect at the time.
- [State v. Andrews, 227 Md. App. 350 (2016)](https://criminaldefenseresources.com/rulings/state-v-andrews/): The Maryland Court of Special Appeals held that people have a reasonable expectation that their cell phones will not be used as real-time tracking devices by police, and that using a cell-site simulator to locate a phone requires a warrant based on probable cause. An order under the pen register statute was not enough, and the evidence was suppressed.
- [United States v. Davis, 785 F.3d 498 (11th Cir. 2015) (en banc)](https://criminaldefenseresources.com/rulings/united-states-v-davis-11th-cir/): The full Eleventh Circuit held that obtaining historical cell-site records from a phone company with a court order under the Stored Communications Act, rather than a warrant, did not violate the Fourth Amendment.
- [Grady v. North Carolina, 575 U.S. 306 (2015)](https://criminaldefenseresources.com/rulings/grady-v-north-carolina/): In a short unsigned opinion, the Court held that a state program that attaches a satellite-based (GPS) monitoring device to a person's body to track the person's movements is a Fourth Amendment search. It sent the case back for the state courts to decide whether the search was reasonable.
- [Lopez-Valenzuela v. County of Maricopa, 770 F.3d 772 (9th Cir. 2014) (en banc)](https://criminaldefenseresources.com/rulings/lopez-valenzuela-v-county-of-maricopa/): The full Ninth Circuit held that Arizona's Proposition 100 laws, which denied bail to all undocumented immigrants charged with a wide range of felonies, violated due process because they were not narrowly tailored and did not provide individualized decisions.
- [Riley v. California, 573 U.S. 373 (2014)](https://criminaldefenseresources.com/rulings/riley-v-california/): The Court held that police generally must get a warrant before searching the digital contents of a cell phone taken from a person who has been arrested.
- [Commonwealth v. Augustine, 467 Mass. 230 (2014)](https://criminaldefenseresources.com/rulings/commonwealth-v-augustine/): The Massachusetts Supreme Judicial Court held that under the Massachusetts Declaration of Rights, the government must get a search warrant based on probable cause before obtaining two weeks of a person's historical cell-site location information from a phone company.
- [State v. Earls, 214 N.J. 564 (2013)](https://criminaldefenseresources.com/rulings/state-v-earls/): The New Jersey Supreme Court held that under the New Jersey Constitution, police must generally get a warrant before obtaining cell-phone location information from a service provider.
- [Maryland v. King, 569 U.S. 435 (2013)](https://criminaldefenseresources.com/rulings/maryland-v-king/): The Court held that when officers arrest someone for a serious offense with probable cause and bring the person to the station, taking a DNA cheek swab is a legitimate booking procedure that is reasonable under the Fourth Amendment, like fingerprinting and photographing.
- [United States v. Olsen, 704 F.3d 1172 (9th Cir. 2013)](https://criminaldefenseresources.com/rulings/united-states-v-olsen/): The Ninth Circuit found that the government did not disclose information about problems with a state crime lab forensic scientist who worked on the case. But the court held the information was not "material" given the other evidence, so the conviction was affirmed.
- [Missouri v. Frye, 566 U.S. 134 (2012)](https://criminaldefenseresources.com/rulings/missouri-v-frye/): The Court held that defense lawyers generally have a duty to tell their clients about formal plea offers from the prosecution that may be favorable. Failing to do so can be ineffective assistance of counsel.
- [United States v. Jones, 565 U.S. 400 (2012)](https://criminaldefenseresources.com/rulings/united-states-v-jones/): The Court held that the government's installation of a GPS tracking device on a person's vehicle, and its use to monitor the vehicle's movements, was a search under the Fourth Amendment.
- [Perry v. New Hampshire, 565 U.S. 228 (2012)](https://criminaldefenseresources.com/rulings/perry-v-new-hampshire/): The Court held that the Due Process Clause requires a preliminary judicial check on the reliability of an eyewitness identification only when the police arranged the suggestive circumstances. Other suggestive circumstances are left to safeguards such as cross-examination and jury instructions.
- [Doody v. Ryan, 649 F.3d 986 (9th Cir. 2011) (en banc)](https://criminaldefenseresources.com/rulings/doody-v-ryan/): The full Ninth Circuit held that a 17-year-old's confession, given after a lengthy overnight interrogation in an Arizona murder investigation, was obtained in violation of Miranda because the warnings were confusing and played down, and that the confession was involuntary. Federal habeas relief was granted.
- [Skinner v. Switzer, 562 U.S. 521 (2011)](https://criminaldefenseresources.com/rulings/skinner-v-switzer/): The Court held that a convicted prisoner seeking DNA testing of crime-scene evidence may bring that claim as a federal civil rights lawsuit under 42 U.S.C. section 1983, rather than only through habeas corpus.
- [State v. Sweeney, 224 Ariz. 107 (App. 2010)](https://criminaldefenseresources.com/rulings/state-v-sweeney/): The Arizona Court of Appeals held that after a traffic stop ended, an officer needed reasonable suspicion to hold the driver longer for a drug-dog sniff. Because there was no reasonable suspicion for that second detention, it was unlawful.
- [District Attorney's Office for the Third Judicial District v. Osborne, 557 U.S. 52 (2009)](https://criminaldefenseresources.com/rulings/district-attorneys-office-v-osborne/): The Court held that there is no freestanding federal constitutional right to obtain evidence for post-conviction DNA testing, and that the state's procedures for post-conviction relief were adequate.
- [Arizona v. Gant, 556 U.S. 332 (2009)](https://criminaldefenseresources.com/rulings/arizona-v-gant/): The Court held that police may search a car after arresting a recent occupant only if the arrested person could reach into the passenger area at the time of the search, or if it is reasonable to believe the car contains evidence of the crime of arrest.
- [United States v. Craighead, 539 F.3d 1073 (9th Cir. 2008)](https://criminaldefenseresources.com/rulings/united-states-v-craighead/): The Ninth Circuit held that questioning in a person's own home can be "custodial" for Miranda purposes when the setting is police-dominated. Courts look at factors such as how many officers were there, whether they were armed, whether the person was restrained or isolated, and whether he was told he was free to leave.
- [Indiana v. Edwards, 554 U.S. 164 (2008)](https://criminaldefenseresources.com/rulings/indiana-v-edwards/): The Court held that a state may require a lawyer for a defendant who is competent to stand trial but who, because of severe mental illness, is not competent to conduct the trial on his or her own.
- [Crawford v. Washington, 541 U.S. 36 (2004)](https://criminaldefenseresources.com/rulings/crawford-v-washington/): The Court held that "testimonial" out-of-court statements from a witness who does not testify at trial cannot be used against the defendant unless the witness is unavailable and the defendant had a prior opportunity to cross-examine that witness.
- [United States v. Erskine, 355 F.3d 1161 (9th Cir. 2004)](https://criminaldefenseresources.com/rulings/united-states-v-erskine/): The Ninth Circuit held that a defendant's decision to give up his lawyer and represent himself was not knowing and intelligent, because the record showed he had not been correctly informed of the maximum penalty he faced. The conviction was reversed.
- [Ring v. Arizona, 536 U.S. 584 (2002)](https://criminaldefenseresources.com/rulings/ring-v-arizona/): The Court held that Arizona's death-penalty system, which let a judge alone find the aggravating factors needed for a death sentence, violated the right to a jury trial. A jury must find those factors.
- [State v. Spreitz, 202 Ariz. 1 (2002)](https://criminaldefenseresources.com/rulings/state-v-spreitz/): The Arizona Supreme Court held that claims of ineffective assistance of counsel should be raised in post-conviction relief proceedings (under Arizona Rule of Criminal Procedure 32), not on direct appeal. Appellate courts will not decide those claims on direct appeal.
- [Apprendi v. New Jersey, 530 U.S. 466 (2000)](https://criminaldefenseresources.com/rulings/apprendi-v-new-jersey/): The Court held that, other than a prior conviction, any fact that raises the penalty for a crime beyond the maximum set by law must be decided by a jury and proved beyond a reasonable doubt.
- [Martinez v. Court of Appeal of California, Fourth Appellate District, 528 U.S. 152 (2000)](https://criminaldefenseresources.com/rulings/martinez-v-court-of-appeal/): The Court held that the Faretta right to self-representation does not extend to a direct appeal. The Constitution does not require states to let a defendant represent himself on appeal from a criminal conviction.
- [Kyles v. Whitley, 514 U.S. 419 (1995)](https://criminaldefenseresources.com/rulings/kyles-v-whitley/): The Court held that whether suppressed evidence is "material" depends on the combined effect of all the withheld evidence, not each item alone. The prosecutor has a duty to learn of favorable evidence known to others acting for the government, including the police.
- [Doggett v. United States, 505 U.S. 647 (1992)](https://criminaldefenseresources.com/rulings/doggett-v-united-states/): The Court held that an eight-and-a-half-year delay between indictment and arrest, caused by the government's negligence, violated the right to a speedy trial, even though the defendant could not point to specific harm to his defense.
- [United States v. Salerno, 481 U.S. 739 (1987)](https://criminaldefenseresources.com/rulings/united-states-v-salerno/): The Court upheld the federal Bail Reform Act of 1984, which allows a court to hold an arrested person before trial if the government shows by clear and convincing evidence that no release conditions will reasonably protect others and the community.
- [United States v. Karo, 468 U.S. 705 (1984)](https://criminaldefenseresources.com/rulings/united-states-v-karo/): The Court held that monitoring a beeper inside a private home, in a place not open to visual surveillance, is a Fourth Amendment search that generally requires a warrant.
- [Strickland v. Washington, 466 U.S. 668 (1984)](https://criminaldefenseresources.com/rulings/strickland-v-washington/): The Court set a two-part test for claims that a defense lawyer was ineffective. First, the lawyer's performance fell below an objective standard of reasonableness. Second, there is a reasonable probability the result would have been different without the lawyer's errors.
- [McKaskle v. Wiggins, 465 U.S. 168 (1984)](https://criminaldefenseresources.com/rulings/mckaskle-v-wiggins/): The Court held that a judge may appoint standby counsel for a self-represented defendant, even over the defendant's objection. But standby counsel may not take over. The defendant must keep actual control over the case presented to the jury, and the jury must still see the defendant as representing himself.
- [United States v. Knotts, 460 U.S. 276 (1983)](https://criminaldefenseresources.com/rulings/united-states-v-knotts/): The Court held that using a radio beeper to follow a car on public roads was not a Fourth Amendment search, because a person traveling on public roads has no reasonable expectation of privacy in movements others could see.
- [Edwards v. Arizona, 451 U.S. 477 (1981)](https://criminaldefenseresources.com/rulings/edwards-v-arizona/): The Court held that once a person in custody asks for a lawyer, police must stop questioning until a lawyer is present, unless the person himself starts further conversation with police.
- [Manson v. Brathwaite, 432 U.S. 98 (1977)](https://criminaldefenseresources.com/rulings/manson-v-brathwaite/): The Court held that reliability is the "linchpin" in deciding whether an identification made after a suggestive procedure can be used. Courts weigh the Biggers factors against the corrupting effect of the suggestive procedure, rather than automatically excluding the identification.
- [Faretta v. California, 422 U.S. 806 (1975)](https://criminaldefenseresources.com/rulings/faretta-v-california/): The U.S. Supreme Court held that the Sixth Amendment gives a person charged with a crime the right to represent himself or herself. A state cannot force a lawyer on a defendant who knowingly and intelligently chooses to go without one.
- [Neil v. Biggers, 409 U.S. 188 (1972)](https://criminaldefenseresources.com/rulings/neil-v-biggers/): The Court held that even when police use a suggestive identification procedure, the identification may still be used if it is reliable under the totality of the circumstances. It listed factors: the witness's opportunity to view the person, the witness's degree of attention, the accuracy of any earlier description, the witness's level of certainty, and the time between the crime and the identification.
- [Barker v. Wingo, 407 U.S. 514 (1972)](https://criminaldefenseresources.com/rulings/barker-v-wingo/): The Court held that the constitutional right to a speedy trial has no fixed deadline. Instead, courts weigh four factors: how long the delay was, the reason for it, whether and when the defendant asserted the right, and whether the delay harmed the defendant.
- [Giglio v. United States, 405 U.S. 150 (1972)](https://criminaldefenseresources.com/rulings/giglio-v-united-states/): The Court held that the prosecution's duty to disclose includes evidence that affects a key witness's credibility, such as a promise of leniency in exchange for testimony. A promise made by one prosecutor is charged to the whole prosecutor's office.
- [State v. Dessureault, 104 Ariz. 380 (1969)](https://criminaldefenseresources.com/rulings/state-v-dessureault/): The Arizona Supreme Court held that when a defendant challenges a pretrial identification, the trial court should hold a hearing outside the jury's presence. The State must show by clear and convincing evidence that the pretrial identification was not unduly suggestive, and if it was, that any in-court identification is not tainted by it.
- [Terry v. Ohio, 392 U.S. 1 (1968)](https://criminaldefenseresources.com/rulings/terry-v-ohio/): The Court held that a police officer may briefly stop a person when the officer has reasonable suspicion, based on specific facts, that criminal activity may be happening. If the officer reasonably believes the person is armed and dangerous, the officer may do a limited pat-down of outer clothing for weapons.
- [Katz v. United States, 389 U.S. 347 (1967)](https://criminaldefenseresources.com/rulings/katz-v-united-states/): The Court held that the government's recording of a man's conversation in a public phone booth, without a warrant, was a search under the Fourth Amendment. The Fourth Amendment protects people, not just places.
- [United States v. Wade, 388 U.S. 218 (1967)](https://criminaldefenseresources.com/rulings/united-states-v-wade/): The Court held that a post-indictment lineup is a critical stage of the prosecution at which the defendant has a right to have a lawyer present. A later in-court identification may still be allowed if the prosecution shows it has a source independent of the improper lineup.
- [Miranda v. Arizona, 384 U.S. 436 (1966)](https://criminaldefenseresources.com/rulings/miranda-v-arizona/): The Court held that statements made during custodial police interrogation cannot be used against the defendant unless police first give warnings: the right to remain silent, that statements can be used in court, the right to a lawyer, and that a lawyer will be appointed if the person cannot afford one.
- [Brady v. Maryland, 373 U.S. 83 (1963)](https://criminaldefenseresources.com/rulings/brady-v-maryland/): The Court held that when the prosecution suppresses evidence favorable to the accused that was requested, it violates due process if the evidence is material to guilt or punishment. This is true whether the prosecutor acted in good faith or bad faith.
- [Gideon v. Wainwright, 372 U.S. 335 (1963)](https://criminaldefenseresources.com/rulings/gideon-v-wainwright/): The Court held that the right to a lawyer is a fundamental right that applies in state courts. States must provide a lawyer to people charged with felonies who cannot afford one.
- [Mapp v. Ohio, 367 U.S. 643 (1961)](https://criminaldefenseresources.com/rulings/mapp-v-ohio/): The Court held that evidence obtained through an unconstitutional search and seizure cannot be used in state criminal trials. This applied the "exclusionary rule" to the states.
- [Stack v. Boyle, 342 U.S. 1 (1951)](https://criminaldefenseresources.com/rulings/stack-v-boyle/): The Court held that bail set higher than an amount reasonably calculated to make sure the defendant shows up for trial is "excessive" under the Eighth Amendment. Bail must be based on standards tied to that purpose and to the individual defendant.