United States v. Crouch

CourtCourt of Appeals for the Fifth Circuit
DecidedApril 20, 1995
Docket93-07719
StatusPublished

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

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United States v. Crouch, (5th Cir. 1995).

Opinion

UNITED STATES COURT OF APPEALS

FOR THE FIFTH CIRCUIT

No. 93-7719

UNITED STATES OF AMERICA, Plaintiff-Appellant,

versus

A. GUY CROUCH, III and MICHAEL J. FRYE, Defendants-Appellees.

Appeal from the United States District Court for the Southern District of Texas

(April 20, 1995)

Before POLITZ, Chief Judge, GARWOOD and BENAVIDES, Circuit Judges.

POLITZ, Chief Judge:

The district court dismissed indictments against A. Guy

Crouch, III and Michael J. Frye which arose out of alleged illegal

banking activity. For the reasons assigned, we affirm.

Background

In March of 1986, while examining the records of Delta Savings

Association of Texas, a failed institution, federal investigators

discovered that the institution had been engaged in a "cash for trash" scheme.1 Delta officials violated federal regulations which

prohibited excessive loans to one borrower by using bogus nominee

borrowers who bore no personal liability for the loans contracted.

Criminal referrals issued for Carl Gerjes, Delta's president,

Robert Ferguson, an involved real estate investor, Crouch, Delta's

attorney and chairman of its board of directors, and Frye who

allegedly acted through a corporate alter ego, JMG Financial, as a

nominee borrower for Ferguson. In 1986 the government began an

investigation into Delta's activities, focusing on Gerjes and

Ferguson, leading to the conviction of Gerjes in 1989 and his

guilty plea conviction on separate but related offenses in 1992, as

well as Ferguson's conviction in 1992. On November 12, 1992 a

19-count indictment was handed up against Crouch and Frye, charging

misapplication of funds, 18 U.S.C. §§ 2, 657; false entries,

18 U.S.C. §§ 2, 1006; false statements, 18 U.S.C. §§ 2, 1014; and

bank fraud, 18 U.S.C. §§ 2, 1344.

Citing the eight-plus years between the alleged crimes in

1984-85 and the indictment, Crouch and Frye asserted prejudice from

the pre-indictment delay and moved for dismissal. A magistrate

judge recommended dismissal because of both presumptive and actual

prejudice caused by the passage of time. Following a de novo

review the district court adopted the recommendation, holding that

1 Delta made loans to real estate investors conditioned on their purchase of property acquired by Delta primarily through prior defaults. The "sale" of this property reduced Delta's liabilities, lowered its required cash reserves, and artificially increased its net worth, thereby evading closer inquiry into its operations.

2 defendants had suffered presumptive prejudice because of the delay

and finding actual prejudice resulting from the delay due to the

unavailability of testimony because of death and memory loss and

the disappearance of exculpatory records. Applying the balancing

test directed in United States v. Brand2 and in United States v.

Townley3 for claimed violations of due process resulting from

pre-indictment delay, the court found that the government's

assigned reason for delay, the lack of resources, did not outweigh

the prejudice suffered by Crouch and Frye. The court dismissed the

indictment; the government timely appealed.

Analysis

The government faults the district court's use of the Brand/

Townley balancing test. Even assuming Crouch and Frye were able to

show prejudice, the government contends that their inability to

demonstrate prosecutorial bad faith for the dilatory indictment

defeated their motion for dismissal. It cites post-Townley

decisions for the proposition that to establish a due process

violation based on pre-indictment delay a defendant must show that

the prosecutor intentionally delayed the indictment to gain

tactical advantage.4

2 556 F.2d 1312 (5th Cir. 1977), cert. denied, 434 U.S. 1063 (1978). 3 665 F.2d 579 (5th Cir.), cert. denied, 456 U.S. 1010 (1982). 4 See United States v. Byrd, 31 F.3d 1329 (5th Cir. 1994); United States v. Neal, 27 F.3d 1035 (5th Cir.), cert. denied, _____ U.S. _____, 115 S.Ct. 1165 (1994); and United States v. Amuny, 767 F.2d 1113 (5th Cir. 1985).

3 In United States v. Marion5 the Supreme Court held that

although the primary protection against undue delay prior to

arrest, indictment, or information is the appropriate statute of

limitations, the due process clause of the fifth amendment offers

some protection from prejudice to a defendant's case arising from

this delay. The Court accepted, as an example, the government's

contention that if it be shown that the government had created the

prejudicial delay as "an intentional device to gain tactical

advantage over the accused,"6 due process would require the

automatic dismissal of the indictment.

Following Marion we began the development of a test for

violations of due process in this context. Despite the Marion

Court's express refusal to "determine when and in what

circumstances actual prejudice resulting from pre-accusation delays

requires the dismissal of the prosecution,"7 in dicta we used the

statement that a showing of prosecutorial bad faith required

automatic dismissal for the very different proposition that such a

showing was a sine qua non for the finding of a due process

violation.8 Because the defendants in those cases were unable to

5 404 U.S. 307 (1971). 6 404 U.S. at 322. 7 Id. 8 See, e.g., United States v. Avalos, 541 F.2d 1100 (5th Cir. 1976), cert. denied, 430 U.S. 970 (1977); United States v. Butts, 524 F.2d 975 (5th Cir. 1975).

Avalos, however, noted a caveat to use of a standard requiring a showing of prosecutorial bad faith, stating:

4 make a showing of prejudice due to delay, we did not apply this

statement in a dispositive ruling.

The Supreme Court next considered this issue in United States

v. Lovasco,9 stating that proof of prejudice was "a necessary but

not sufficient element of a due process claim, and that the due

process inquiry must consider the reasons for the delay as well as

the prejudice to the accused,"10 including the inquiry whether the

delayed prosecution violates "elementary standards of fair play and

decency"11 and "fundamental conceptions of justice which lie at the

base of our civil and political institutions."12 After balancing

the prejudice caused by an 18-month delay against the government's

reason for delay -- its continuing investigation -- the Lovasco

Court upheld dismissal of the indictment.

The Lovasco Court also noted that following Marion neither it

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Related

United States v. Beszborn
21 F.3d 62 (Fifth Circuit, 1994)
United States v. Byrd
31 F.3d 1329 (Fifth Circuit, 1994)
United States v. Marion
404 U.S. 307 (Supreme Court, 1971)
United States v. Lovasco
431 U.S. 783 (Supreme Court, 1977)
United States v. MacDonald
435 U.S. 850 (Supreme Court, 1978)
Hoo v. United States
484 U.S. 1035 (Supreme Court, 1988)
Doggett v. United States
505 U.S. 647 (Supreme Court, 1992)
United States v. Erle W. McGough
510 F.2d 598 (Fifth Circuit, 1975)
United States v. Alexander J. Barket
530 F.2d 189 (Eighth Circuit, 1976)
United States v. Eugene Lovasco, Sr.
532 F.2d 59 (Eighth Circuit, 1976)
United States v. Jose Avalos and Rudolfo Castrillon
541 F.2d 1100 (Fifth Circuit, 1976)
United States v. Charles Demetrios Brand
556 F.2d 1312 (Fifth Circuit, 1977)
United States v. Richard Lee Willis
583 F.2d 203 (Fifth Circuit, 1978)
United States v. Esteban Ramos
586 F.2d 1078 (Fifth Circuit, 1978)
United States v. August W. Durnin
632 F.2d 1297 (Fifth Circuit, 1980)
United States v. Franklin Eugene Nixon
634 F.2d 306 (Fifth Circuit, 1981)
United States v. Clarence Duane Hendricks
661 F.2d 38 (Fifth Circuit, 1981)
United States v. Michael Ray Townley
665 F.2d 579 (Fifth Circuit, 1982)

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