LOVE v. United States

CourtDistrict Court, D. New Jersey
DecidedMay 8, 2025
Docket3:22-cv-02768
StatusUnknown

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

Bluebook
LOVE v. United States, (D.N.J. 2025).

Opinion

NOT FOR PUBLICATION

UNITED STATES DISTRICT COURT DISTRICT OF NEW JERSEY

JUSTIN LOVE, Petitione _ . etitioner, Civil Action No. 22-2768 (MAS) V. OPINION UNITED STATES OF AMERICA, Respondent.

SHIPP, District Judge This matter comes before the Court on Petitioner Justin Love’s motion to vacate sentence brought pursuant to 28 U.S.C. § 2255. (ECF No. 1.) Following an order to answer, the Government filed a response to the amended motion (ECF No. 6), to which Petitioner replied following the appointment of counsel (ECF No. 24). For the following reasons, this Court will deny the motion, and will deny Petitioner a certificate of appealability. I. BACKGROUND Petitioner’s convictions in this matter arise out of his participation in interstate dogfighting operations in contravention of applicable federal law. The Third Circuit briefly described the facts underlying this operation on direct appeal as follows: [Petitioner and his codefendants] were convicted of various federal crimes in connection with a dogfighting conspiracy. The conspiracy was uncovered by federal agents monitoring wiretaps authorized as part of an investigation into Anthony “Monte” Gaines. Over the course of six weeks beginning in October 2015, agents intercepted several days’ worth of conversations between Mr. Gaines and others, including [Petitioner’s codefendant] Ware and [Petitioner], regarding various aspects of the dogfighting activity, which resulted

in several convictions including [Petitioner’s]. The trial evidence showed that [Petitioner and his codefendants] maintained dogs that were bred, trained, and kept for fighting; that Mr. Ware intended to enter at least one dog in a fight; and that [Petitioner] actually entered dogs in fights, one of which was recorded in videos found on his cell phone. Further, possession of certain dogs passed between [Petitioner, his codefendants,] and their co-conspirators at various times.

[Petitioner] was convicted of (i) conspiracy to sponsor and exhibit dogs in animal fighting ventures, contrary to 7 U.S.C. § 2156(a)(1) and 18 U.S.C. § 49 and in violation of 18 U.S.C. § 371; (ii) conspiracy to sell, buy, possess, train, transport, deliver, and receive dogs for the purposes of having the dogs participate in animal fighting ventures, contrary to 7 U.S.C. § 2156(b) and 18 U.S.C, § 49 and in violation of 18 U.S.C. § 371; (iti) two counts of knowingly purchasing and receiving a dog for purposes of having the dog participate in an animal fighting venture, contrary to 7 US.C. § 2156(b), 18 U.S.C. § 49, and 18 U.S.C. § 2; and (iv) six counts of knowingly possessing a dog for purposes of having the dog participate in an animal fighting venture, contrary to 7 U.S.C. § 2156(b), 18 U.S.C. § 49, and 18 U.S.C. § 2. At trial, [Petitioner] attempted to establish that his participation in the conspiracy was in his capacity as an informant in a dogfighting investigation. Specifically, [he] sought to develop the theory that he had cooperated with Larry Donato, then a New Jersey SPCA officer, when he “engaged in activities designed to cultivate information about dog fighting ventures and persons involved in illegal dog fighting activities.” The Government argued that [Petitioner] was asserting a public authority defense and that he had failed to comply with the notice requirements set forth in Federal Rule of Criminal Procedure 12.3.

On the fourth day of trial, the Government petitioned the District Court to preclude the testimony of any witnesses who would have testified in support of a public authority defense, including “Government witnesses who have been subject to cross- examination under this theory.” When the issue was first raised, [Petitioner’s] counsel, Mr. Powell, argued that Rule 12.3 was inapplicable. In a written submission and subsequent oral presentations, Mr. Powell explained that [Petitioner] sought to assert an “innocent intent” defense, as opposed to a public authority

defense. [Although counsel disclaimed he was attempting to raise a public authority defense, he also argued the Government had not been prejudiced and he should be permitted to develop such a defense if the facts permitted, despite asserting he only intended to pursue the innocent intent strategy directly. The District Court initially denied the Government’s motion, which the Government subsequently renewed multiple times. The first renewal was based on new discovery the Government had obtained from Mr. Powell, including text messages in which [Petitioner] appeared to tell Donato that he was working for a federal government employee. The District Court deemed the issue unripe and declined to rule on the renewed motion. The Government next raised the issue at a sidebar while [Petitioner] was on the stand, after Mr. Powell had asked him various permutations of the question “Everything we’ve seen in the case that relates to you, to your understanding were those all activities undertaken by you at the behest of Mr. Donato?” Prior to this sidebar, [Petitioner] had also testified about unproduced emails with Donato and had discussed his interactions with “an alleged public official named John for whom [the defense] ha[d] a recording that [the Government] never received.” [Petitioner “had also testified throughout his direct examination about the informant relationship he had purportedly developed with Mr. Donato and other police officers, as well as the actions he took to further these relationships.”| The District Court did not rule on the motion at this time. After [Petitioner’s] testimony had concluded, the District Court found he had certainly “asserted an actual exercise of public authority.” The District Court granted the Government’s renewed motion. The immediate result of this ruling was the preclusion of certain testimony of Special Agent Nicholas Tranchitella. Mr. Powell had proffered that Agent Tranchitella’s testimony would be relevant “as to whether or not he had an opportunity to interview Mr. Donato and as to whether or not Mr. Donato is actually a real person and areal former employee of the SPCA.” The District Court also charged the jury regarding the public authority defense, over Mr. Powell’s objection, and did not instruct the jury regarding an innocent intent defense. In its jury charge, the District Court stated that [Petitioner] should not be found guilty if the jury were to find that (1) a government official directed [Petitioner] to engage in the conduct charged against him, (2) the official had actual or apparent authority to grant such authorization, and (3) in engaging in the conduct, [Petitioner] had reasonably relied on the official’s actual or apparent authorization.

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LOVE v. United States, Counsel Stack Legal Research, https://law.counselstack.com/opinion/love-v-united-states-njd-2025.