Delgado v. United States

District of Columbia Court of Appeals·Decided September 17, 2026·No. 25-CF-0563·Published

Opinion

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DISTRICT OF COLUMBIA COURT OF APPEALS No. 25-CF-0563

NICOLAS DELGADO, APPELLANT, V.

UNITED STATES, APPELLEE.

Appeal from the Superior Court of the District of Columbia (2020-FD3-005782)

(Carmen G. McLean, Judge)

(Submitted June 2, 2026 Decided September 17, 2026)

Timothy Cone was on the brief for appellant.

Jeanine Ferris Pirro, United States Attorney, and Chrisellen R. Kolb and Nicholas G. Miranda, Assistant United States Attorneys, were on the brief for appellee.

Before EASTERLY, DEAHL, and SHANKER, Associate Judges.

SHANKER, Associate Judge: After a jury convicted appellant Nicolas Delgado of first-degree theft and threatening to injure or kidnap a person, the trial court, in addition to sentencing him to a period of incarceration and supervised release, imposed assessments of $1,000 for each count pursuant to the Victims of Violent Crime Compensation Act (VVCCA). D.C. Code §§ 4-515 & -516. On appeal, Mr.

Delgado argues that the assessments violate the Eighth Amendment to the United States Constitution because they are excessive fines. We assume without deciding that VVCCA assessments are punitive for purposes of the Eighth Amendment but conclude that the assessments imposed in this case were not excessive. We therefore affirm.

I. Background

On a July morning in 2020, Mr. Delgado was at the home of his romantic partner, C.P. The pair had been seeing each other for about a year and a half, and Mr. Delgado had moved into C.P.’s condominium. While preparing for their day, the couple started arguing, with Mr. Delgado accusing C.P. of cheating on him. Although C.P. denied his accusations, Mr. Delgado grew angry and began to physically and verbally abuse C.P. He grabbed C.P. and dragged her to the bathroom, where he forced her to sit on the toilet while he “chopp[ed]” off her hair. Mr. Delgado then “grabbed” designer handbags that C.P. kept in her closet and several pieces of her valuable jewelry and “stuffed” them in “several gym bags.” Mr. Delgado instructed C.P. to head to her car. Before the two left the condo, Mr. Delgado told C.P. that he would kill her and her family if she reported the incident to the police.

After driving to an automatic teller machine and forcing C.P. to withdraw hundreds of dollars, Mr. Delgado took the money and drove C.P. back to her residence. When they arrived, he reminded C.P. not to call the police and reiterated his threat that he would “come for” her if she reported him. He then left in C.P.’s car, with her handbags and jewelry still in his possession. C.P. reported the incident to law enforcement about a week later.

A grand jury indicted Mr. Delgado on eleven counts related to the incident, including first-degree theft, in violation of D.C. Code §§ 22-3211 and -3212(a), and threatening to injure or kidnap a person, in violation of D.C. Code § 22-1810. A jury convicted Mr. Delgado of only those two counts. The trial court sentenced Mr. Delgado to concurrent terms of twenty-eight months of imprisonment to be followed by three years of supervised release and ordered him to pay $3,638.60 in restitution in connection with C.P.’s stolen possessions. The court also imposed on Mr. Delgado assessments of $1,000 for each conviction to be paid to the Crime Victims Compensation Fund pursuant to the VVCCA. D.C. Code §§ 4-515 & -516. Mr. Delgado did not object to the VVCCA assessments at sentencing. He timely appealed.

II. Analysis

Mr. Delgado argues that the VVCCA assessments imposed by the trial court violate the Eighth Amendment’s Excessive Fines Clause. In his view, the VVCCA assessments satisfy the two-prong inquiry the Supreme Court has established for determining whether a forfeiture violates the Excessive Fines Clause: (1) the assessments are at least partially punitive in nature, Austin v. United States, 509 U.S. 602, 610 & n.6 (1993) (explaining that the question that must be resolved when deciding whether the Eighth Amendment’s Excessive Fines Clause applies is “whether punishment is being imposed”), and (2) the assessments are “grossly disproportional to the gravity” of his offenses, United States v. Bajakajian, 524 U.S. 321, 334 (1998) (holding that “a punitive forfeiture violates the Excessive Fines Clause if it is grossly disproportional to the gravity of a defendant’s offense”). The government disagrees on both fronts and also contends that Mr. Delgado failed to preserve his argument in the trial court and cannot satisfy the plain-error standard of review.

We decline to address the issue of forfeiture and instead assume without deciding that Mr. Delgado preserved his constitutional challenge to his sentence. We also need not decide whether VVCCA assessments are punitive for purposes of the

Eighth Amendment. 1 Because we conclude that the assessments here were not excessive, we affirm on that basis.

A. Legal Framework and Standard of Review

The Eighth Amendment provides that “[e]xcessive bail shall not be required, nor excessive fines imposed, nor cruel and unusual punishments inflicted.” U.S. Const. amend. VIII. As mentioned, when addressing whether the Excessive Fines Clause applies, “two fundamental principles” shape our analysis. One 1995 Toyota Pick-Up Truck v. District of Columbia (1995 Toyota), 718 A.2d 558, 560 (D.C. 1998).

“First, the limitation on excessive fines is meant to curb the government’s power to extract payments, whether in cash or in kind, as punishment for some offense.” Id. (emphasis in original) (citation modified). “Therefore, whether or not a government-initiated forfeiture of property is a ‘fine’ for purposes of the Excessive

1 Our decisions in Tornero v. United States, 335 A.3d 104 (D.C. 2025), and Lopez-Ramirez v. United States, 171 A.3d 169 (D.C. 2017), that VVCCA assessments are not “fines” as a statutory matter are not controlling on the constitutional question whether such assessments are punitive. See Austin, 509 U.S. at 610-11 (noting that how a sanction is characterized does not dictate whether, as a constitutional matter, it at least partially serves punitive purposes). Cf. Jenkins v. United States, 80 A.3d 978, 1003 (D.C. 2013) (recognizing the principle that a statutorily-compliant sentence does not shield that sentence from constitutional scrutiny).

Fines Clause depends not on its outward characterization as either civil or criminal, but rather on whether it is a form of punishment.” Id. (citing Austin, 509 U.S. at 610). “If there is an element of punishment in the forfeiture, it comes within the purview of the Excessive Fines Clause notwithstanding the fact that it may also serve remedial purposes.” Id.

The second “controlling principle relates to the severity of a fine allowed by the Eighth Amendment.” Id. at 561. “Once it is established that a forfeiture is a fine within the meaning of the Eighth Amendment, a gross disproportionality test must be applied to determine constitutional excessiveness . . . .” Id. That test, as established by the Supreme Court, requires that “[t]he amount of the forfeiture must bear some relationship to the gravity of the offense that it is designed to punish.” Bajakajian, 524 U.S. at 334. Thus, “a punitive forfeiture violates the Excessive Fines Clause if it is grossly disproportional to the gravity of a defendant’s offense.” Id.

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