United States v. Burke

CourtDistrict Court, District of Columbia
DecidedOctober 21, 2025
DocketCriminal No. 2024-0265
StatusPublished

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

Bluebook
United States v. Burke, (D.D.C. 2025).

Opinion

UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA

UNITED STATES OF AMERICA

v. Case No. 1:24-cr-00265-1 (TNM)

ROBERT P. BURKE,

Defendant.

MEMORANDUM ORDER

A jury trial resulted in ADM Robert Burke’s (USN, Ret.) conviction on four felonies.

See Judgment, ECF No. 350. He has since appealed his conviction and sentence to the D.C.

Circuit, and he now moves for a stay of the execution of his sentence and continuance of his

release pending the Circuit’s resolution of that appeal. For the reasons below, the Court denies

his motion.

I.

Earlier this year, a jury found Burke guilty of four crimes related to his role in a bribery

scheme between himself and a government vendor that offered him future employment. See

Verdict Form, ECF No. 168. Burke was found guilty of (1) conspiracy under 18 U.S.C. § 371,

(2) bribery under 18 U.S.C. § 201(b)(2)(A), (3) having a financial conflict of interest in a

government matter under 18 U.S.C. § 208(a), and (4) concealment of material facts under 18

U.S.C. § 10001(a)(1). Following those convictions, the Court sentenced Burke to 60 months’

incarceration as to his conspiracy, conflict-of-interest, and concealment-of-material-facts

charges, and 72 months’ incarceration as to the bribery charge, all to run concurrently. See

Minute Entry, Sept. 16, 2025. The Court also ordered that 36 months of supervised release

follow each count, also to run concurrently, and imposed a $400 special assessment and $86,748.08 forfeiture. Id. After sentencing, the Court permitted Burke to self-surrender, and he

has remained on personal recognizance. Id.

Burke has appealed his conviction and sentence to the D.C. Circuit. Notice of Appeal,

ECF No. 352. Around that time, the Probation Office ordered Burke to self-surrender to begin

his imprisonment term today. See Mot. to Extend Self-Surrender Date, ECF No. 354. Following

the Court’s denial of Burke’s motion to extend that self-surrender date, Minute Order, October

16, 2025, Burke moved to stay the execution of his sentence and continue his release pending the

resolution of his appeal. Mot. to Stay Execution of Sentence, ECF No. 355 (“Motion to Stay”).

Because Burke has not shown a substantial question to present on appeal, the Court denies his

motion.

II.

In 18 U.S.C. § 3143(b), Congress gave criminal defendants an avenue to secure their

release from federal custody pending disposition of their appeals. But that path is available only

in limited circumstances. See United States v. Perholtz, 836 F.2d 554, 555–56 (D.C. Cir. 1988).

A district court must find two conditions met before ordering the release of a defendant whose

appeal is pending before a circuit. First, the Court must find “by clear and convincing evidence

that the person is not likely to flee or pose a danger to the safety of any other person or the

community if released.” 18 U.S.C. § 3143(b)(1)(A). And second, the Court must find “that the

appeal is not for the purpose of delay and raises a substantial question” that is “likely to result in”

reversal, a new trial, a noncustodial sentence, or a custodial sentence which will have fully

expired by the time the appeal is decided. Id. § 3143(b)(1)(B). The Court takes each

requirement in turn.

2 A.

On the first score, the Court finds—and the Government does not disagree—that Burke

presents no flight risk or danger to the community. While on pretrial release, Burke complied

with the Court’s conditions and made required appearances, and no evidence suggests his

behavior would change now.

B.

On the second score, Burke falls short. He has not shown that any of his four challenges

presents a substantial question likely to result in reversal or a new trial.

Impeachment Evidence. Start with Burke’s claim that the Court impermissibly excluded

evidence that would have impeached his non-testifying co-conspirators, Charlie Kim and

Meghan Messenger. Mot. to Stay at 3. When ruling on evidentiary motions like this one, trial

judges possess broad discretion, and appellate courts will reverse such rulings only in the event

of an abuse of that discretion. See English v. District of Columbia, 651 F.3d 1, 7 (D.C. Cir.

2011). This deferential standard impedes Burke’s success on appeal.

Even without it, though, Burke still likely misses the mark. At trial, the Court excluded

the evidence that Burke now says is inadmissible. Defense wanted to introduce an email chain

featuring messages from Kim on grounds that Kim’s messages constituted “prior inconsistent

statements” that would serve as impeachment evidence under Federal Rule of Evidence 806,

which concerns impeachment of non-testifying declarants. Mot. to Stay at 3; May 12, 2025, PM

Trial Tr. 3:9–7:2. The trouble for Burke is that, as the Court explained, Federal Rule of

Evidence 806 applies when “the declarant is being inconsistent with the testimony that he gave.”

Id. 10:12–10:16. Indeed, Rule 806 allows impeachment evidence only if it would be admissible

had Kim actually testified. See Fed. R. Evid. 806. And as for testifying witnesses, it is a “basic

3 rule of evidence” that before “prior inconsistent statements may be used to impeach [his]

credibility,” courts “must be persuaded that the statements are indeed inconsistent.” United

States v. Hale, 422 U.S. 171, 176 (1975). 1 Here, the Court found that Burke wanted to use the

relevant evidence not to show Kim’s inconsistency with any of his own statements, but to show

“inconsistency with other facts elsewhere.” May 12, 2025, PM Trial Tr. 10:14. That finding

provided reasonable grounds for exclusion.

Neither of Burke’s citations alters that conclusion. His first example, United States v.

Williams-Davis, 90 F.3d 490, 512 (D.C. Cir. 1996), involved the Government’s discovery

obligations related to co-conspirators’ statements. And the second, “Watkins v. United States,

No. 00-CF-540 (D.C. Cir. 2004),” is no more than an incomplete citation that the Court cannot

verify. That makes for a weak claim of an abuse of discretion.

Rule of Completeness. Turn to Burke’s second claim, that the Court circumvented

Federal Evidence Rule 106 by admitting into evidence only portions of Burke’s interview with

law enforcement. Mot. to Stay 5. Federal Rule of Evidence 106 provides that if “a party

introduces all or part of a writing or recorded statement, an adverse party may require the

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Related

Graves v. United States
150 U.S. 118 (Supreme Court, 1893)
United States v. Hale
422 U.S. 171 (Supreme Court, 1975)
English v. District of Columbia
643 F.3d 297 (D.C. Circuit, 2011)
Alvin T. Morrison v. United States
365 F.2d 521 (D.C. Circuit, 1966)
United States v. Kevin Williams-Davis
90 F.3d 490 (D.C. Circuit, 1996)
United States v. Christian Borda
848 F.3d 1044 (D.C. Circuit, 2017)
United States v. Thiam
934 F.3d 89 (Second Circuit, 2019)

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