United States v. David Darby

CourtCourt of Appeals for the Third Circuit
DecidedJune 24, 2026
Docket24-3091
StatusUnpublished

This text of United States v. David Darby (United States v. David Darby) is published on Counsel Stack Legal Research, covering Court of Appeals for the Third 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. David Darby, (3d Cir. 2026).

Opinion

NOT PRECEDENTIAL

UNITED STATES COURT OF APPEALS FOR THE THIRD CIRCUIT ______________

No. 24-3091 ______________

UNITED STATES OF AMERICA

v.

DAVID B. DARBY, Appellant ______________

On Appeal from the United States District Court for the Middle District of Pennsylvania (D.C. No. 1:21-CR-00081) U.S. District Judge: Honorable Christopher C. Conner ______________

Submitted Under Third Circuit L.A.R. 34.1(a) May 11, 2026 ______________

Before: SHWARTZ, MASCOTT, and McKEE, Circuit Judges.

(Filed: June 24, 2026) ______________

OPINION* ______________

* This disposition is not an opinion of the full court and, pursuant to I.O.P. 5.7, does not constitute binding precedent. SHWARTZ, Circuit Judge.

David B. Darby appeals his convictions and sentence. For the following reasons,

we will affirm.

I

From jail calls and wiretap recordings,1 physical surveillance, controlled

purchases, and witnesses, law enforcement confirmed that Darby distributed oxycodone,

cocaine, and fentanyl on multiple occasions and made one fentanyl sale that led to the

death of a confidential informant, Kayla Bertone. A search of a location affiliated with

Darby led to the recovery of two firearms. Based on this evidence, Darby was charged

with and convicted of violating federal drug, gun, and money laundering laws.

II

A

Darby first argues that the District Court violated his Sixth Amendment right by

seating an out-of-district juror. We disagree.

Criminal defendants are entitled to trial “by an impartial jury of the State and

district wherein the crime shall have been committed.” U.S. Const. amend. VI. Together

with the Venue Clause, see U.S. Const. art. III, § 2, cl. 3, this so-called Vicinage Clause

governs “jury composition” and “narrows the place where trial is permissible by

specifying” where a “jury must be drawn from.” Smith v. United States, 599 U.S. 236,

1 Any challenge to the District Court’s order denying his motion to suppress the wiretap evidence fails because the wiretap application was supported by probable cause based on, among other things, Darby’s recorded jail calls and controlled drug buys. United States v. Tehfe, 722 F.2d 1114, 1118 (3d Cir. 1983). 2 245 (2023).

During voir dire in open court, a prospective juror informed the District Court that

he had recently moved from the Middle District to the Eastern District of Pennsylvania.2

At sidebar in the presence of counsel,3 the juror told the Court that he had moved two

weeks prior.4 No one objected to his serving on the jury. Thus, Darby’s objection to his

service was waived. See United States v. Gonzalez, 949 F.3d 30, 37 (1st Cir. 2020);

United States v. Novod, 923 F.2d 970, 978 (2d Cir.), aff’d on reh’g, 927 F.2d 726 (2d

Cir. 1991) (determining challenge to juror’s residency was waived where defendant “did

not object when the juror first identified her county of residence; nor did he do so once he

became aware of the actual boundaries of the [judicial district] during the colloquy”);

United States v. Haywood, 452 F.2d 1330, 1332 (D.C. Cir. 1971) (“[A] party who fails to

object to the service of a juror on grounds of residence . . . should be deemed to have

2 See 28 U.S.C. § 118 (delineating judicial districts of Pennsylvania). 3 Darby was present in the courtroom when the juror initially explained his residency but was not present during the subsequent conversation at sidebar. See United States v. Johnson, 677 F.3d 138, 141-42 (3d Cir. 2012) (“[T]he decision to have a criminal defendant present—and in close proximity to individual jurors—during individual voir dire conducted at sidebar is tactical and does not require the defendant’s express consent.”); see also United States v. Gagnon, 470 U.S. 522, 528 (1985) (“The district court need not get an express ‘on the record’ waiver from the defendant for every trial conference which a defendant may have a right to attend.”). 4 After the juror disclosed his new residence, the Court responded: “I think we’re okay based on that. You just need to have lived in our jurisdiction for at least one year prior to your jury service.” App. 672. Counsel for Darby’s co-defendant added that the date of service was counted from the juror’s completion of the questionnaire. These statements likely referred to a requirement under the Jury Selection and Service Act of 1968 (“JSSA”), which bars from jury service anyone who has “not . . . resided for a period of one year within the judicial district.” 28 U.S.C. § 1865(b)(1). Darby does not assert a JSSA violation. 3 waived the objection.”). Furthermore, the decision whether to strike a juror is reserved

for an attorney’s professional judgment. See Gov’t of Virgin Islands v. Weatherwax, 77

F.3d 1425, 1434 (3d Cir. 1996); see also United States v. Oakes, 680 F.3d 1243, 1249

(10th Cir. 2012) (observing the “widely accepted view that the decision whether to strike

a prospective juror during jury selection is one for defense counsel”). Because Darby

waived his right to challenge the juror, he is not entitled to relief.

Although the Supreme Court has noted the importance of the Vicinage and Venue

Clauses in Smith, 599 U.S. at 245, it has not discussed the application of the Vicinage

Clause in the jury selection context, nor has it opined on its waivability. Our case law

observes that “[d]espite its basis in the Constitution, venue in the criminal context

continues to occupy a lesser station in the hierarchy of constitutionally-derived rights,”

that it can be waived, and that “the standard for finding a waiver of venue is less rigorous

than that for finding a waiver of the rights to trial by jury, to confront one’s accusers and

to be free from self-incrimination.” United States v. Perez, 280 F.3d 318, 328 (3d Cir.

2002); see also United States v. Auernheimer, 748 F.3d 525, 541 n.9 (3d Cir. 2014)

(emphasizing importance of venue but holding “[w]e in no way imply that venue cannot

be waived by the defendant by failing to object to it in a timely fashion”). In light of the

similar role and importance of the Venue and Vicinage Clauses in criminal jury trials,

and ours Court’s longstanding precedent on waiver of venue, challenges to the Vicinage

Clause can be similarly waived here under those principles. See United States v. Sandini,

803 F.2d 123, 127 (3d Cir. 1986) (“[O]bjections to venue are waived if not raised in a

timely manner”).

4 B5

Next, Darby claims that the District Court unduly limited his cross-examination of

Alycia Logsdon—who purchased pills from Darby, sold one pill to a friend, and became

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Douglas v. Alabama
380 U.S. 415 (Supreme Court, 1965)
United States v. Gagnon
470 U.S. 522 (Supreme Court, 1985)
Delaware v. Fensterer
474 U.S. 15 (Supreme Court, 1985)
Kentucky v. Stincer
482 U.S. 730 (Supreme Court, 1987)
Crawford v. Washington
541 U.S. 36 (Supreme Court, 2004)
United States v. Theotis Haywood
452 F.2d 1330 (D.C. Circuit, 1971)
United States v. Tehfe
722 F.2d 1114 (Third Circuit, 1983)
United States v. Sandini
803 F.2d 123 (Third Circuit, 1986)
Eddie Griffin v. John Spratt and J. Kevin Kane
969 F.2d 16 (Third Circuit, 1992)
United States v. Steven Sallins
993 F.2d 344 (Third Circuit, 1993)

Cite This Page — Counsel Stack

Bluebook (online)
United States v. David Darby, Counsel Stack Legal Research, https://law.counselstack.com/opinion/united-states-v-david-darby-ca3-2026.