United States v. Chapman

CourtCourt of Appeals for the Ninth Circuit
DecidedMay 8, 2026
Docket24-4939
StatusPublished

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

Bluebook
United States v. Chapman, (9th Cir. 2026).

Opinion

FOR PUBLICATION

UNITED STATES COURT OF APPEALS FOR THE NINTH CIRCUIT

UNITED STATES OF AMERICA, No. 24-4939 D.C. No. Plaintiff - Appellee, 2:20-cr-00091- JCM-DJA-1 v.

JOHN MATTHEW CHAPMAN, OPINION Defendant - Appellant.

Appeal from the United States District Court for the District of Nevada James C. Mahan, District Judge, Presiding

Argued and Submitted January 7, 2026 San Francisco, California

Filed May 8, 2026

Before: Ronald M. Gould, Jacqueline H. Nguyen, and Mark J. Bennett, Circuit Judges.

Opinion by Judge Gould 2 USA V. CHAPMAN

SUMMARY*

Criminal Law

The panel vacated John Chapman’s conviction for kidnapping resulting in death in violation of 18 U.S.C. § 1201(a)(1) and remanded for a new trial. The federal kidnapping statute has three primary elements, and four when death is alleged to have resulted from the kidnapping: (1) that the defendant “seizes, confines, inveigles, decoys, kidnaps, abducts, or carries away” the victim; (2) that the defendant “holds” the victim; (3) that the victim is “willfully transported in interstate or foreign commerce” or that the defendant uses “any means, facility, or instrumentality of interstate or foreign commerce” in committing the kidnapping; and (4) that the kidnapping resulted in death. Affirming the district court’s denial of Chapman’s post- verdict motion for acquittal, the panel held (1) the “holding” element of the federal kidnapping statute does not require a use of physical force, and an individual may be “held” against their will through a means of deception in an inveiglement case; and (2) there was sufficient evidence for a jury to conclude that Chapman “held” the victim by non- physical forms of “holding,” including deception. The panel vacated the conviction and remanded for a new trial, however, because, as the parties conceded, the district court improperly coerced the jury’s verdict. First,

* This summary constitutes no part of the opinion of the court. It has been prepared by court staff for the convenience of the reader. USA V. CHAPMAN 3

the district court gave an Allen charge without disclosing to the parties that it had received on the first day of deliberations two substantive jury notes that contained the numerical breakdown of the jurors’ votes. This was impermissible jury coercion. Second, the district court’s comments when canvassing a juror were coercive under the totality of the circumstances. Third, the deliberation of only thirty minutes after receiving the Allen charge favors a finding of coercion. There were, finally, other indicia of coerciveness. Affirming the district court’s denial of his motion to suppress his confession, the panel held that Chapman knowingly and intelligently waived his Miranda rights and that his confession was voluntary.

COUNSEL

Andrew C. Noll (argued), Trial Attorney, Appellate Section; Matthew R. Galeotti, Acting Assistant Attorney General; Criminal Division, United States Department of Justice, Washington, D.C.; Penelope J. Brady, Peter H. Walkingshaw, Megan Rachow, Adam M. Flake, and Steven J. Rose, Assistant United States Attorneys; Sigal Chattah, United States Attorney; Office of the United States Attorney, United States Department of Justice, Las Vegas, Nevada; for Plaintiff-Appellee. Jeremy C. Baron (argued), Ellesse Henderson, and Nicholas Wolfram, Assistant Federal Public Defenders; Rene L. Valladares, Federal Public Defender; Office of the Federal Public Defender, Las Vegas, Nevada; for Defendant- Appellant. 4 USA V. CHAPMAN

OPINION

GOULD, Circuit Judge:

Appellant John Chapman (“Chapman”) appeals the district court’s denial of his post-verdict motion for acquittal, contending that there was insufficient evidence to convict and that the district court used an incorrect standard to determine if there was “holding” within the meaning of the kidnapping statute, 18 U.S.C. § 1201(a)(1). He also appeals his conviction for kidnapping resulting in death in violation of 18 U.S.C. § 1201(a)(1), contending that a new trial is warranted because of improper jury coercion. Chapman also contends on appeal that the district court erred in its denial of his motion to suppress his confession because of an invalid waiver of Chapman’s Miranda rights and that the district court erred in determining that his confession was voluntary. Finally, Chapman challenges the district court’s issuance of particular jury instructions. We have jurisdiction under 28 U.S.C. § 1291. Because the district court improperly coerced the jury’s verdict, we vacate Chapman’s conviction and remand for a new trial. We affirm the district court’s denial of the motion for acquittal, however, and hold, for the first time in this Circuit, that the “holding” element of the federal kidnapping statute can be satisfied through non-physical force. Finally, we affirm the district court’s denial of the motion to suppress and hold that Chapman knowingly and intelligently waived his Miranda rights and that his confession was voluntary.1

1 Because the jury instruction concerning the meaning of “holding” within 18 U.S.C. § 1201(a)(1) is relevant to Chapman’s claim there was insufficient evidence to convict, we address that jury instruction. But as USA V. CHAPMAN 5

I. FACTS AND PROCEDURAL HISTORY A Chapman suffers from autism, Tourette syndrome, Obsessive-Compulsive Disorder, and Attention Deficit Hyperactivity Disorder (“ADHD”), and he experienced language and other developmental delays while growing up. Chapman began a romantic relationship with Jamie Feden (“Feden”) in 2009 that lasted on-and-off until her death in 2019. Feden was born with VATER syndrome, a rare developmental syndrome which caused her to be small in stature, resulted in breathing issues, asthma, and eye problems, and prevented her from driving. Chapman married another woman in 2018, unbeknownst to Feden, but continued a romantic relationship with Feden, unbeknownst to his wife. In September 2019, Feden and Chapman took a road trip to Las Vegas, which they had been planning for almost a year. Months before the trip, Chapman searched the internet for answers to questions about murdering an individual and disposing of the body. Specifically, on June 23, 2019, Chapman viewed and followed a question on Quora, a website allowing individuals to post questions and answers, asking “[i]f I’m a suspect in a murder but a body is never found, can I be charged?” On the same day, Chapman also interacted with a question reading “[y]ou have just murdered someone. Where would you hide the body.” On August 12, 2019, Chapman interacted with a question asking whether an individual could be charged “if the police think something

to his other jury instruction challenges, we do not address them here because there will be a new trial and those other challenges can then be raised to the district court. 6 USA V. CHAPMAN

happened to my girlfriend” because she was reported missing and refused to speak or confirm anything with the police. Chapman also had viewed and followed questions about whether acid would dissolve human flesh and when a dead body would begin to float after drowning. On September 5, 2019, Chapman interacted with a question asking “[y]ou just murdered someone.

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United States v. Chapman, Counsel Stack Legal Research, https://law.counselstack.com/opinion/united-states-v-chapman-ca9-2026.