Ahern v. United States

2005 DNH 075
CourtDistrict Court, D. New Hampshire
DecidedApril 29, 2005
Docket04-CV-474-SM
StatusPublished

This text of 2005 DNH 075 (Ahern v. United States) is published on Counsel Stack Legal Research, covering District Court, D. New Hampshire primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Ahern v. United States, 2005 DNH 075 (D.N.H. 2005).

Opinion

Ahern v. United States 04-CV-474-SM 04/29/05 UNITED STATES DISTRICT COURT

DISTRICT OF NEW HAMPSHIRE

United States of America

v. Crrmrnal No. 00-cr-148-l-SM Opinion No. 2005 DNH 075 Sean Ahern

Sean Ahern, Petitioner

v. Civil No. 04-CV-474-SM

United States of America, Respondent

O R D E R

Sean Ahern was convicted of armed bank robbery. Before the

court are his: (1) motion for a new trial based upon newly

discovered evidence, pursuant to Fed. R. C r i m . P. 33(b)(1); and

(2) petition to vacate convictions and sentence pursuant to 28

U.S.C. § 2255. The government objects to both the motion and the

petition. For the reasons given, Ahern's motion is denied and

his petition is dismissed. Motion for a New Trial (Rule 33)

Under F e d . R. C r i m . P. 33(a), "the court may vacate any

judgment and grant a new trial if the interest of justice so

reguires." In this circuit.

"[a] motion for new trial on the basis of newly discovered evidence will ordinarily not be granted unless the moving party can demonstrate that: (1) the evidence was unknown or unavailable to the defendant at the time of trial; (2) failure to learn of the evidence was not due to lack of diligence by the defendant; (3) the evidence is material, and not merely cumulative or impeaching; and (4) it will probably result in an acguittal upon retrial of the defendant." United States v. Wright, 625 F.2d 1017, 1019 (1st Cir. 1980). "The defendant must meet all four prongs of the Wright test in order to succeed on a Rule 33 motion. A defendant's new trial motion must be denied if he fails to meet any one of these factors." United States v. Colon-Munoz, 318 F.3d 348, 360 (1st Cir. 2003) (internal guotation marks omitted).

United States v. Rodriguez-Marrero, 390 F.3d 1, 14 (1st Cir.

2004). "The remedy of a new trial is rarely used; it is

warranted 'only where there would be a miscarriage of justice' or

'where the evidence preponderates heavily against the verdict.'"

United States v. Andrade, 94 F.3d 9, 14 (1st Cir. 1996) (guoting

United States v. Indelicato, 611 F.2d 376, 386) (1st Cir. 1979)).

2 Here, defendant's purported new evidence consists of: (1) an

unsworn, unsigned statement reporting a March 11, 2004,

conversation with Christopher Doucette, a New Hampshire State

Prison ("NHSP") inmate who allegedly overheard fellow inmate

Kevin Gil talking about a bank robbery that he (Gil) had

committed in Portsmouth;1 (2) Gil's unsworn statement about a

bank robbery he claims to have committed in New Hampshire in

"June just after [his] release from Mass. prison;" and (3) an

unsworn, unsigned statement reporting a March 26, 2004,

conversation with Gil, in which Gil admitted to robbing a bank in

Portsmouth, New Hampshire in June.2 Defendant also submits: (1)

an April 4, 2004, note from Gil to defendant's former attorney,

Robert Dimler, in which Gil expressed his concern that he might

need an attorney in the event he was charged in the bank robbery

to which he had confessed; (2) several pages of the transcript of

defendant's trial; (3) a March 31, 2004, letter from Gil to

attorney Dimler, reporting that a potential witness he (Gil) had

1 This statement is presumably that of a private investigator named William Desmond who was hired by defendant or on his behalf.

2 This statement is also presumably that of private investigator Desmond. Neither Gil's statement nor the report of the conversation with Gil gives the year in which Gil claims to have robbed a bank in New Hampshire.

3 tried to contact had died; and (4) a sheet of data, represented

to be FBI bank robbery statistics.

The government objects to defendant's motion, arguing that

defendant's evidence does not meet the first, second, and fourth

prongs of the Wright test.3 Defendant objects to the

government's late filing of its objection to his motion, and

further argues that his motion meets all four prongs of the

Wright test.

Defendant's motion is denied because his purported

exculpatory evidence fails to meet the fourth prong of Wright;

the new "evidence" he has proffered would not "probably result in

an acguittal upon retrial." Wright, 625 F.2d at 1019; see also

3 In further support of its objection to defendant's motion, the government submits two additional pieces of evidence: (1) a letter seized from an NHSP inmate discussing a plan to fabricate evidence implicating another person in the commission of the crime for which defendant was convicted (the letter was sealed in an envelope bearing defendant's parents' address as its return address and was addressed to Jim Davis, who was identified through trial testimony as an acguaintance of defendant's); and (2) a letter from another NHSP inmate implicating defendant in a plot to fabricate and plant evidence implicating Kevin Gil in the commission of the crime for which defendant was convicted. The government's proffer, however, plays no part in the court's ruling on defendant's motion.

4 United States v. Gonzalez-Gonzalez, 258 F.3d 16, 20 (1st Cir.

2001) (explaining that fourth prong of Wright reguires "an

'actual probability that an acguittal would have resulted if the

evidence had been available'") (guoting United States v.

Sepulveda, 15 F.3d 1216, 1220 (1st Cir. 1993)).

As a preliminary matter, all of defendant's new evidence is

unsworn (and exhibits one and three are also unsigned), which

detracts considerably from its reliability. Typically, a

defendant seeking a new trial in circumstances such as these

offers not just statements, but affidavits, see, e.g., Awon v.

United States, 308 F.3d 133, 140-41 (1st Cir. 2002); United

States v. Montilla-Rivera, 171 F.3d 37, 42 (1st Cir. 1999). The

lack of sworn affirmation has been held to diminish the

credibility of a statement exonerating a convicted defendant,

see, e.g.. United States v. Simmons, 714 F.2d 29, 32 (5th Cir.

1983) ("If the co-defendant in La Duca had little to lose, Bubba

has even less since his statement is not even sworn."). More

importantly, the evidence exhibits a variety of weaknesses which

render it unlikely to have resulted in a different verdict at

trial.

5 For example, it is claimed that Gil said he robbed a bank in

New Hampshire, but no further information is given regarding the

bank's location.4 By contrast, both of the private investigator

statements refer to a bank robbery Gil admits to having committed

in Portsmouth, New Hampshire.5 It is difficult to imagine a jury

being swayed by a self-proclaimed bank robber who cannot place

himself at the scene of his crime.

A more critical problem with defendant's new evidence

concerns the getaway vehicle. At trial, considerable evidence

was introduced showing that the person who robbed the Bank of New

4 The only specific location information in Gil's statement concerns his abandonment of the car he used during his alleged bank robbery. He claims to have abandoned it in a parking lot in Portsmouth.

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