United States v. Griffin

CourtDistrict Court, District of Columbia
DecidedJuly 2, 2021
DocketCriminal No. 2021-0092
StatusPublished

This text of United States v. Griffin (United States v. Griffin) 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. Griffin, (D.D.C. 2021).

Opinion

UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA

UNITED STATES OF AMERICA

v. Case No. 21-cr-00092 (TNM) COUY GRIFFIN,

Defendant.

MEMORANDUM OPINION AND ORDER

Couy Griffin faces charges for entering a restricted area outside the U.S. Capitol on

January 6, 2021. He now moves to dismiss the Information, arguing that because the Capitol

Police—not the Secret Service—barricaded the area, the charged offenses do not cover his

alleged conduct. See 18 U.S.C. § 1752. The Court does not read the statute to provide such

tenuous security for Secret Service protectees. It will therefore deny his motion and permit the

case to proceed.

I.

The Court treats the allegations in the Government’s Complaint as true for now. See

United States v. Sunia, 643 F. Supp. 2d 51, 60 (D.D.C. 2009). According to it, a joint session of

Congress gathered at the Capitol on January 6 to certify the Electoral College results of the 2020

Presidential Election. Compl. Ex. 1 (“Gov’t Facts”) at 1–2, ECF No. 1-1. 1 Vice President Mike

Pence presided over, and Vice President-elect Kamala Harris attended, the joint session. Am.

Information at 1, ECF No. 31. To protect the Capitol and the people and proceedings inside, the

1 All page citations refer to the page numbers generated by this Court’s CM/ECF system, and all exhibit numbers refer to the numbered attachments to the CM/ECF filings.

1 U.S. Capitol Police (“USCP”) erected a perimeter of barriers around the Capitol grounds. Gov’t

Facts at 1. USCP officers patrolled the barriers, and signage read “Area Closed by order of the

United States Capitol Police Board.” Id.

As the election certification proceedings began, a large crowd of protestors approached

the Capitol. Id. at 2. In the crowd was Defendant Couy Griffin. Id. at 3. Griffin is the founder

of an advocacy group, “Cowboys for Trump.” Id. He and a videographer traveled to

Washington, D.C., on January 6 to protest the results of the 2020 Presidential Election. Id. at 3.

After attending a rally hosted by President Trump on the National Mall, Griffin headed toward

the Capitol as the crowd formed around the barricades. Id. at 3–4. Griffin noticed that “there

was some fencing up and they were saying that you could not go any further because this was

being reserved for Joe Biden and his inauguration.” Id. at 6.

Numerous protestors, including Griffin, breached the barricades and entered the area

around the Capitol. Id. at 3. Griffin and his videographer climbed up a permanent wall and onto

the Capitol’s west-facing patio. Id. at 4. Griffin then took a temporary staircase to the outside

deck of the Capitol, where the Presidential Inauguration was set to occur in a few weeks. Id. at

4, 6. There Griffin borrowed a bullhorn and led a group of protestors in prayer. Id. at 4. He

remained on the deck for about an hour and a half before voluntarily leaving the Capitol grounds

with his videographer. Id. at 3.

Three days later, the FBI received a tip that Griffin had entered the Capitol grounds on

January 6. Id. The FBI also discovered Griffin’s videographer had recorded much of his visit.

Id. at 4.

The Government charged Griffin by Information with misdemeanor violations of 18

U.S.C. § 1752(a)(1) and (2). Information at 1–2, ECF No. 14. Section 1752(a)(1) criminalizes

2 “knowingly enter[ing] or remain[ing] in any restricted building or grounds without lawful

authority to do so.” 18 U.S.C. § 1752(a)(1). Section 1752(a)(2) further prohibits “knowingly,

and with intent to impede or disrupt the orderly conduct of Government business or official

functions, engag[ing] in disorderly or disruptive conduct in, or within such proximity to, any

restricted building or grounds . . . .” 18 U.S.C. § 1752(a)(2).

The Government moved to detain Griffin before trial. It described Griffin’s political

views as “inflammatory, racist, and at least borderline threatening advocacy.” Gov’t’s Mem. in

Supp. of Pretrial Detention at 2, ECF No. 3. The Government also highlighted the gun rights

advocacy of Cowboys for Trump, as well as allegedly violent statements made by Griffin. Id. at

2–3. A magistrate judge ordered Griffin detained. Minute Entry (Feb. 1, 2021). But Chief

Judge Howell granted Griffin’s motion to overturn the pretrial detention order, Minute Entry

(Feb. 5, 2021), and he remains on pretrial release with conditions.

Griffin now moves to dismiss the charges for failure to state an offense. Def.’s Second

Mot. to Dismiss the Am. Information (“Def.’s Mot.”) at 5, ECF No. 32. 2 He argues that the

Capitol was not restricted by the U.S. Secret Service, a requisite for a § 1752 offense. Id. at 13–

16. The Government opposes Griffin’s motion but does not contest his allegation that the USCP

was responsible for the restrictions. See Gov’t’s Resp. to Def.’s Mot. (“Gov’t Resp.”), ECF No.

33. The Court granted Def.’s Motion for a Hearing and heard arguments from both sides.

Griffin’s motion to dismiss is ripe for disposition.

2 The Court denied as moot Defendant’s initial Motion to Dismiss after the Government filed an Amended Complaint. See Min. Order (May 18, 2021).

3 II.

Before trial, a defendant in a criminal case may move to dismiss an information for

failure to state an offense. Fed. R. Crim. P. 12(b)(3)(B)(v). A valid information must set out

“the elements of the offense intended to be charged and sufficiently apprise the defendant of

what he must be prepared to meet.” United States v. Pickett, 353 F.3d 62, 67 (D.C. Cir. 2004).

The Government must state the essential elements of the crime and allegations of “overt acts

[constituting the offense] with sufficient specificity.” United States v. Childress, 58 F.3d 693,

720 (D.C. Cir. 1995).

When ruling on a motion to dismiss, the Court “is limited to reviewing the face of” the

Information and “the language used to charge the crimes.” United States v. Payne, 382 F. Supp.

3d 71, 73 (D.D.C. 2019) (cleaned up). The Court must accept the allegations of the Information

as true. Id. at 74. At this stage, “[t]he operative question is whether the allegations, if proven,

would be sufficient to permit a jury to find that the crimes charged were committed.” United

States v. Sanford, Ltd., 859 F. Supp. 2d 102, 107 (D.D.C. 2012).

III.

Griffin contends that he cannot be found guilty under 18 U.S.C. § 1752 as charged

because the offense requires that the Secret Service—not another agency—restrict the area

covered by the statute. See Def.’s Mot. at 6–30. The Government responds that the statute does

not compel this narrow reading. 3 Gov’t Resp. at 9–17. The Government is right.

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