United States v. Degregoris

CourtDistrict Court, District of Columbia
DecidedJanuary 6, 2025
DocketCriminal No. 2023-0057
StatusPublished

This text of United States v. Degregoris (United States v. Degregoris) 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. Degregoris, (D.D.C. 2025).

Opinion

UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA

UNITED STATES OF AMERICA : : v. : Criminal Action No.: 23-57 (RC) : ROBERT DEGREGORIS, : Re Document Nos.: 50, 51 : Defendant. :

MEMORANDUM OPINION

DENYING MOTION FOR A NEW TRIAL; DENYING MOTION FOR A JUDGMENT OF ACQUITTAL

I. INTRODUCTION

Robert DeGregoris (“Defendant”), based on his findings of guilt at a bench trial, moves

for a new trial and judgment of acquittal. Defendant was found guilty on Counts One through

Four of the Indictment charging him with Civil Disorder; Entering and Remaining in a Restricted

Building or Grounds; Disorderly and Disruptive Conduct in a Restricted Building or Grounds;

and Impeding Passage Through the Capitol Grounds or Buildings, in violation of 18 U.S.C.

§ 231(a)(3), 18 U.S.C. § 1752(a)(1), 18 U.S.C. § 1752(a)(2), and 40 U.S.C. § 5104(e)(2)(E),

respectively. See Def.’s Mot. New Trial, ECF No. 50; Def.’s Mot. J. of Acquittal, ECF No. 51

(collectively, “Defendant’s Motions”). Defendant moves for a renewed judgment of acquittal1

because he alleges that the Government did not provide sufficient evidence to demonstrate that

Defendant knew that he was trespassing or that his actions obstructed the police. In the

alternative, he moves for a new trial on the basis that the Court improperly granted the

Government’s motion in limine. See Order Granting Gov’t’s Unopposed Mot. in Limine, ECF

1 During the bench trial, Defendant originally moved for a judgment of acquittal orally at the close of the Government’s case in chief. No. 45. The Government opposes Defendant’s Motions, arguing that Defendant’s convictions

were supported by sufficient evidence beyond a reasonable doubt and that he is not entitled to a

new trial nor a judgment of acquittal. For the foregoing reasons, the Court denies the

Defendant’s Motions.

II. FACTUAL BACKGROUND

Briefly summarized below are the pertinent facts that the Government proved beyond a

reasonable doubt at the bench trial, which underly Defendant’s conviction. On January 6, 2021,

Defendant traveled from his home in Virginia to Washington, D.C. to attend the Stop the Steal

rally taking place at the Ellipse. Defendant traveled to the Capitol, arriving on Capitol grounds

early that afternoon. He then made his way to the entrance to the Capitol where the most violent

fighting occurred—the mouth of the Lower West Terrace Tunnel (the “Tunnel”). Defendant

stayed at or near that entrance for approximately twenty minutes, where he urged on the large

crowd of rioters standing at a distance from the Tunnel, watched as other rioters assaulted police

officers defending the Tunnel, and assisted another rioter in obtaining a position from which he

could kick at those officers. During that same timeframe, Defendant was hit with OC spray that

was fired by the officers guarding the Tunnel, yet Defendant more or less held his ground. Later,

when Defendant was hit with a blast of OC spray directly in the face, he began leaving the

Tunnel and, eventually, Capitol grounds. On his way out, Defendant stopped for a videotaped

interview with another rioter in which he stated that he and the other rioters were not going

anywhere. He also texted friends and family about his participation in the riot, expressing to his

wife that he had gone to the Capitol “to stand up for something [he] believe[d] in with every

fiber of [his] soul.” Ex. 803.

2 On February 22, 2023, a federal grand jury returned an indictment charging Defendant

with four offenses stemming from his conduct on January 6, 2021. Count One charged

Defendant with civil disorder in violation of 18 U.S.C. § 231(a)(3). Count Two charged him

with entering and remaining in a restricted building or grounds in violation of 18 U.S.C.

§ 1752(a)(1). Count Three charged Defendant with disorderly and disruptive conduct in a

restricted building or grounds in violation of 18 U.S.C. § 1752(a)(2). Count Four charged him

with impeding passage through the Capitol grounds or buildings in violation 40 U.S.C.

§ 5104(e)(2)(E). Defendant waived his right to a jury trial on June 27, 2024, see Min. Entry,

June 27, 2024, and the case proceeded to a three-day bench trial which commenced on July 8,

2024. On October 4, 2024, the Court rendered its verdict finding Defendant guilty on all counts.

Min. Entry, Oct. 4, 2024.

III. LEGAL STANDARDS

Federal Rule of Criminal Procedure 29(c)(1) provides that “[a] defendant may move for a

judgment of acquittal, or renew such a motion, within 14 days after a guilty verdict or after the

court discharges the jury, whichever is later.” This is a high hurdle to surmount. See United

States v. Hale-Cusanelli, 628 F. Supp. 3d 320, 324 (D.D.C. 2022). When considering such a

motion, the court must “consider[ ] th[e] evidence in the light most favorable to the government”

and uphold a guilty verdict if “any rational trier of fact could have found the essential elements

of the crime beyond a reasonable doubt.” United States v. Wahl, 290 F.3d 370, 375 (D.C. Cir.

2002). In other words, the court must determine whether “a reasonable juror must necessarily

have had a reasonable doubt as to the defendants’ guilt.” United States v. Weisz, 718 F.2d 413,

437 (D.C. Cir. 1983). A motion for judgment of acquittal “succeeds only where the

3 Government’s case is legally defective or has suffered a significant failure of proof.” United

States v. Cappuccio, 2023 WL 6975931, at *1 (D.D.C. Oct. 23, 2023).

Under Rule 33, “the court may vacate any judgment and grant a new trial if the interest of

justice so requires.” Fed. R. Crim. P. 33(a). Motions under Rule 33 are disfavored, however,

and “viewed with great caution.” United States v. Borda, 786 F. Supp. 2d 25, 31 (D.D.C.

2011) (cleaned up). Courts “sparingly” exercise their authority to order a new trial, reserving it

for “extraordinary circumstances where the evidence preponderates heavily against the verdict”

and when any error “affects a defendant’s substantial rights.” Id. at 32 (cleaned up). Granting a

new trial “is warranted only in those limited circumstances where a serious miscarriage of justice

may have occurred.” United States v. Wheeler, 753 F.3d 200, 208 (D.C. Cir. 2014) (internal

quotation marks omitted). The Court has “broad discretion” in deciding a motion for a new trial.

Id. The party seeking a new trial bears the burden of proving that it is justified.

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