United States v. Freeling

31 F.R.D. 540, 1962 U.S. Dist. LEXIS 5961
CourtDistrict Court, S.D. New York
DecidedNovember 26, 1962
StatusPublished
Cited by7 cases

This text of 31 F.R.D. 540 (United States v. Freeling) is published on Counsel Stack Legal Research, covering District Court, S.D. New York primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
United States v. Freeling, 31 F.R.D. 540, 1962 U.S. Dist. LEXIS 5961 (S.D.N.Y. 1962).

Opinion

EDELSTEIN, District Judge.

The defendants are charged in a thirteen count indictment filed May 17, 1961. The first two counts allege the use of the mails in furtherance of a scheme to [542]*542defraud, 18 U.S.C. § 1341 (1958)/1 Counts 3-6 allege use of interstate wire and radio facilities in furtherance of said scheme, 18 U.S.C. § 1343 (1958).2 Counts 7-13 allege transportation in interstate commerce of stolen securities and monies, 18 U.S.C. § 2314 (1958).3 In brief, the indictment alleges a scheme to defraud the Capitol Hill State Bank of Oklahoma City of approximately $1,-500.00 of cash and securities.

Stolen securities and cash were allegedly transmitted to New York by Houlihan and Preeling under a guise that the securities were to be retained by the defendant Legere’s bank, the Grand Bahama Bank and Trust Company, for safekeeping. The scheme’s coup de grace, it is alleged, was the conversion of these stolen assets to the defendants’ personal use, and the defendants’ subsequent use of the cash to purchase the controlling stock of the Capitol Hill State Bank.

Sub judice are motions by the defendant Houlihan, joined by the defendant Legere, to dismiss the indictment on [543]*543three grounds, i. e.,4 (1) improper selection of the Grand Jury; (2) improper interrogation of the defendant Houlihan before the Grand Jury; and (3) defendant Houlihan’s alleged immunity from prosecution pursuant to 12 U.S.C. § 1820 (d), as amended 12 U.S.C.A. § 1820(d) (Supp. 1962). In addition, Houlihan and Legere attack counts 3-6 which charge use of interstate wire and radio in furtherance of a scheme to defraud, as duplicitous and seek to have them dismissed. Finally, these two defendants move pursuant to Rule 21(b), Federal Rules of Criminal Procedure to transfer, “in the interests of justice”, the trial to another district.5

Before passing to consider the merits of these objections, the court must determine the threshold issue of whether or not these motions are timely made. The Government, before joining issue with the defendant on the merits of their claims, urges that the motions are “grossly untimely” and that they should be denied without a consideration of their merits. The Government relies on Rule 12(b) (3), Fed.R.Crim.P., which requires that the motion attacking the indictment or the institution of the prosecution “shall be made before the plea is entered, but the court may permit it to be made within a reasonable time thereafter.” 6 Failure to make a motion attacking the indictment or information before plea is entered or within the time period set by the court for making such objections results in a waiver of those objections unless the court, in the exercise of its discretion, grants the erring defendant relief from the waiver. See Notes of Advisory Committee, Rule 12 (b), 18 U.S.C.A.; Poliafico v. United States, 237 F.2d 97 (6th Cir. 1956), cert. denied, 352 U.S. 1025, 77 S.Ct. 590, 1 L.Ed.2d 597 (1957); Cleaver v. United States, 238 F.2d 766 (10th Cir. 1956); Scales v. United States, 260 F.2d 21, 44-46 (4th Cir. 1958), aff’d, 367 U.S. 203, 259, 81 S.Ct. 1469, 6 L.Ed.2d 782 (1959); United States v. Greater Blouse, Etc., Contractor’s Ass’n., 177 F.Supp. 213 (S.D.N.Y.1959). A defendant seeking an adjudication of tardily made motions [544]*544.has the burden of demonstrating that these motions are nevertheless made within a reasonable time because of the presence of special circumstances.

The defendants claim that because of special circumstances, which the court will consider infra, the motions should be deemed to be timely and should, therefore, be disposed of on their merits. In its deliberations on the question of timeliness, the court is not without guidelines. In this connection, an examination of the history of Rule 12(b) (3), Fed.R.Crim.P. and a review of its application by the courts is helpful.

The promulgation of Rule 12(b) (3) changed fundamentally the criminal motion practice in the Federal courts. Before the effective date of the Criminal Rules, motions attacking the indictment and alleging defects in the institution of the prosecution had to be labeled meticulously. Moreover, the motions had to be brought within specifically designated times. The most commonly used motions were the plea in abatement, the motion to quash, and the demurrer. The courts developed technical distinctions between these three pre-trial motions and the choice of the incorrect form could result in the denial of relief, often in meritorious cases. See Orfield, Pleadings and Motions Before Trial in Federal Criminal Procedure, 29 Fordham L.Rev. 1, 11-26 (1960); Preliminary Draft, Federal Rules of Criminal Procedure, pp. 51-65 (May 3, 1943). More specifically, an attack on the irregularity in the selection of the Grand Jury had to be raised by a plea in abatement or motion to quash and had to be filed within ten days after the defendant was arraigned.7

These niceties of common law criminal pleading and the inflexible time deadlines for raising defenses and objections were eliminated by the Criminal Rules. By the abolition of demurrers, pleas in abatement, and pleas in bar, procedure was greatly simplified. All objections are now raised by motion. Judge Holtzoff, the Secretary to the Advisory Committee and a member of the subcommittee that drafted Rule 12, has described this change and has likewise stated the purpose of the new rule as follows:

“In order that they may not be used for dilatory purposes, the courts are granted power to determine when motions may be made. This discretion is vested in the district court by Rule 12(b) (3) which provides * * * The purpose of this limitation is to empower the District Court to bar the making of last minute motions, the purpose or the effect of which is to delay the trial.”

See Holtzoff, A Criminal Case in the Federal Courts, pp. 11-12, Rules of Criminal Procedure and Criminal Code (West Publishing Co. 1960).

With these inflexible and antique distinctions of time and form thus abolished, Rule 12(b) (3) invested the district court with discretionary power to “permit” motions to be made within a reasonable time after the plea was entered. Notes of Advisory Committee on the Criminal Rules, Rule 12(b) (3), 18 U.S.C.A. The cases and comments cited by the Advisory Committee in its Notes, provided the district courts, during Rule 12(b) (3)’s infancy, with some measure of guidance relating to the exercise of this newly found discretion.

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Cite This Page — Counsel Stack

Bluebook (online)
31 F.R.D. 540, 1962 U.S. Dist. LEXIS 5961, Counsel Stack Legal Research, https://law.counselstack.com/opinion/united-states-v-freeling-nysd-1962.