United States v. Germine

CourtDistrict Court, District of Columbia
DecidedJuly 25, 2025
DocketCriminal No. 2022-0161
StatusPublished

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

Opinion

UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA

UNITED STATES OF AMERICA v. Criminal Action No. 22-161 (JDB) JOLY GERMINE, Defendant.

MEMORANDUM OPINION

In May 2025, Joly Germine stood trial for one count of conspiracy to commit hostage

taking and sixteen counts of hostage taking related to the October 2021 kidnapping of sixteen

American missionaries in Haiti by the Haitian gang 400 Mawozo. The government alleged that

Germine, a leader of the gang who was in Haitian prison at the time, had directed the gang to

kidnap the missionaries and use them to negotiate Germine’s release from prison. At the close of

the government’s case-in-chief, Germine moved for a judgment of acquittal, which the Court

denied. After the close of all evidence, Germine renewed his motion for a judgment of acquittal,

on which the Court reserved its decision until the parties had submitted post-trial briefing. On

May 16, the jury returned verdicts of guilty on all seventeen counts. The parties then briefed the

renewed motion for judgment of acquittal, as well as Germine’s alternative motion for a new trial.

For the following reasons, the Court will deny the motions.

Background

In May 2022, a grand jury returned a one-count indictment charging Germine with

conspiracy to commit hostage taking in violation of 18 U.S.C. § 1203(a), to which Germine pled

not guilty. See Indictment [ECF No. 1] at 2–3; Minute Entry (May 11, 2022). The grand jury

returned a superseding indictment in July 2022, adding sixteen charges of hostage taking and 1 aiding and abetting in violation of 18 U.S.C. §§ 1203(a), 2. See Superseding Indict. [ECF No. 10]

at 8–9. Section 1203(a) “makes extraterritorial hostage-taking a criminal offense when the victim

is a United States national.” United States v. Straker, 800 F.3d 570, 582 (D.C. Cir. 2015); 18

U.S.C. § 1203(a). Counts 2–17 of the superseding indictment charged Germine with the hostage

taking of each of the sixteen American missionaries kidnapped by 400 Mawozo in October 2021.

See Superseding Indict. at 8–9. 1

Trial commenced on May 6, 2025. See Minute Entry (May 6, 2025). After the government

rested, Germine moved for a judgment of acquittal on all counts. See Trial Tr. (May 14, 2025

AM) [ECF No. 111] (“May 14 AM Tr.”) at 1781:25–1782:21, 1784:10–16. The Court denied the

motion, concluding “the evidence [wa]s plainly sufficient to sustain a conviction” on all counts.

See id. at 1785:18–23. But the Court did not preclude Germine from renewing his motion after

the close of all evidence in the case, see id. at 1785:23–25, which Germine then did, see Trial Tr.

(May 15, 2025 PM) [ECF No. 114] (“May 15 PM Tr.”) at 2044:11–2045:2. This time, Germine

argued the government had presented insufficient evidence of the U.S. nationality of ten of the

sixteen hostages, as charged in Counts 2–5 and 9–14 with violations of 18 U.S.C. § 1203(a). See

id. at 2044:11–2046:14. The government disagreed, emphasizing that multiple witnesses had

testified that the sixteen hostages were American and there was no contrary evidence in the record.

See id. at 2047:22–2048:6. The Court reserved ruling on the motion to permit the parties to brief

the issue in writing following trial. See id. at 2048:21–2049:1.

The jury returned its verdict on May 16, finding Germine guilty on all seventeen counts.

See Minute Entry (May 16, 2025). The same day, the government submitted an initial notice

1 At trial, the government presented evidence that 400 Mawozo took hostage a group of seventeen missionaries—sixteen Americans and one Canadian. The superseding indictment does not charge Germine with the hostage taking of the Canadian missionary, so the Court generally refers to only the sixteen American hostages at issue here.

2 providing record citations where it had adduced evidence of the hostages’ nationality. See Not.

Regarding Nationality of Victims [ECF No. 86]. Following trial, the parties briefed Germine’s

renewed motion for a judgment of acquittal and motion for a new trial. See Renewed Mot. J.

Acquittal & Alt. Request New Trial [ECF No. 117] (“Mot.”); Gov’t’s Opp’n Def.’s Mot. [ECF

No. 119] (“Opp’n”); Def.’s Reply Opp’n (ECF No. 120] (“Reply”). The motion is now ripe for

decision.

Analysis

I. Motion for Judgment of Acquittal

Federal Rule of Criminal Procedure 29(a) provides in relevant part that “after the close of

all the evidence, the court on the defendant’s motion must enter a judgment of acquittal of any

offense for which the evidence is insufficient to sustain a conviction.” Subsection (b) permits the

court to “reserve decision on the motion . . . and decide the motion . . . after [the jury] returns a

verdict of guilty.” See Rule 29(b). Because the Court so reserved its decision, it “must decide the

motion on the basis of the evidence at the time the ruling was reserved”—here, after the close of

all evidence. See id. 2

“In assessing a Rule 29 motion, the Court ordinarily construes the evidence in the light

most favorable to the government and must uphold the jury’s verdict if ‘any rational trier of fact

could have found the essential elements of the crime beyond a reasonable doubt.’” United States

v. Green, 735 F. Supp. 3d 8, 17 (D.D.C. 2024) (quoting United States v. Wahl, 290 F.3d 370, 375

(D.C. Cir. 2002) (emphasis in original)); Jackson v. Virginia, 443 U.S. 307, 319 (1979). Put

another way, a court may grant a motion for a judgment of acquittal only when “a reasonable juror

2 The Court is not limited to the evidence in the record at the conclusion of the government’s case-in-chief, because the Court denied Germine’s first motion for a judgment of acquittal made at that time. See May 14 AM Tr. at 1781:25–1782:25. Germine’s operative motion is his renewed motion made at the close of all evidence. See May 15 PM Tr. at 2044:11–2045:2.; Mot. at 1. Because closing arguments are not evidence, see, e.g., May 15 PM Tr. at 2148:9–12, the Court does not consider Germine’s arguments related to the government’s closing argument here.

3 must necessarily have had a reasonable doubt as to the defendant[’s] guilt.” United States v.

Weisz, 718 F.2d 413, 437 (D.C. Cir. 1983) (emphasis in original).

Germine challenges the sufficiency of the evidence as to Counts 2–17, arguing that the

government did not produce sufficient evidence that each hostage was a U.S. national as required

by 18 U.S.C. § 1203(a). 3 A “national of the United States” in § 1203(a) is defined by reference to

the Immigration and Nationality Act as “a citizen of the United States,” Straker, 800 F.3d at 585

(quoting 8 U.S.C.

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United States v. Germine, Counsel Stack Legal Research, https://law.counselstack.com/opinion/united-states-v-germine-dcd-2025.