United States v. Helmich

521 F. Supp. 1246, 1981 U.S. Dist. LEXIS 14511
CourtDistrict Court, M.D. Florida
DecidedAugust 26, 1981
Docket81-61-Cr-J-B
StatusPublished
Cited by14 cases

This text of 521 F. Supp. 1246 (United States v. Helmich) is published on Counsel Stack Legal Research, covering District Court, M.D. Florida primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
United States v. Helmich, 521 F. Supp. 1246, 1981 U.S. Dist. LEXIS 14511 (M.D. Fla. 1981).

Opinion

OPINION AND ORDER DENYING DEFENDANT’S MOTION TO DISMISS INDICTMENT

SUSAN H. BLACK, District Judge.

The Court has for consideration defendant’s Motion to Dismiss Indictment, filed on July 29, 1981. Defendant filed his Supplemental Memorandum of Law on August 14, 1981; the government filed its response on August 18, 1981. The Court heard oral argument on August 20, 1981.

Defendant’s motion outlines four different points as grounds for dismissal of the instant indictment. They are: 1) that Counts II through IV are barred by the statute of limitations; 2) that Count I is violative of Wharton’s Rule; 3) that Counts II through IV fail to allege the occurrence of any action within the territorial jurisdiction of the United States; and 4) that “preindictment delay” has violated defendant’s sixth amendment right to speedy trial and his fifth amendment right to due process of law. The Court will address each of these points in turn.

I. Statute of Limitations

Defendant is charged with violation of 18 U.S.C. § 794, which includes a provision that the maximum penalty for violation of that section is death. 1 The government has *1248 accordingly taken the position that the statute of limitations applicable to this case appears in 18 U.S.C. § 3281. Section 3281 provides in pertinent part that “[a]n indictment for any offense punishable by death may be found at any time without limitation .... ” Defendant maintains, however, that 18 U.S.C. § 3282 (general five-year statute of limitations for “any offense, not capital .... ”), rather than section 3281, should apply to alleged violations of 18 U.S.C. § 794, in light of the holdings of Furman v. State of Georgia, 408 U.S. 238, 92 S.Ct. 2726, 33 L.Ed.2d 346 (1972) and its progeny. See, e. g., Gregg v. Georgia, 428 U.S. 153, 96 S.Ct. 2909, 49 L.Ed.2d 859 (1976); United States v. Kaiser, 545 F.2d 467 (5th Cir. 1977). Furman held that capital punishment imposed under a statute which grants complete and unfettered discretion to the sentencing authority constitutes cruel and unusual punishment in violation of the eighth and fourteenth amendments. Because the death penalty provision of 18 U.S.C. § 794 is, therefore, apparently unconstitutional, 2 defendant argues that section 794 is no longer an “offense punishable by death” for which an indictment “may be found at any time without limitation.” If section 3281 were found inapplicable to the instant case, the governing statute of limitations would be that provided in section 3282 (five years). Because Counts II through IV of the indictment allege acts which occurred, at the latest, during 1963, 3 the instant action would be time-barred if section 3282 were held to apply.

The serious nature of the offense with which defendant has been charged provides the touchstone for the government’s argument that it should be considered, for the purposes of section 3281, a “capital offense.” Although the applicability of section 3281 to section 794 post Furman is a case of the first impression, the Court is not completely without precedent in the area of continued application of statutory provisions which prescribe particular procedures to be followed when an accused is faced with a “capital” crime. The courts which have carefully addressed this issue have followed a similar process of reasoning. They have, essentially, attempted to “look behind” the particular procedure in question in an effort to determine whether the sole reason for it was the defendant’s potential exposure to the death penalty, or whether Congress had other rationales relating to the complexity or grave nature of the offenses punishable by death. See, e. g., United States v. Kennedy, 618 F.2d 557 (9th Cir. 1980) (special treatment of bail condi *1249 tions for those charged with “capital” crimes derives from nature of offense charged and not from fact that potential penalty is death); United States v. Shepherd, 576 F.2d 719, 727-29 (7th Cir.), cert. denied, 439 U.S. 852, 99 S.Ct. 158, 58 L.Ed.2d 155 (1978) (reason for “two counsel rule” and “other procedural provisions giving defendants added rights in capital cases, is humane rather than pragmatic”; holding “two counsel rule” inapplicable after Furman); United States v. Watson, 496 F.2d 1125 (4th Cir. 1973) (reaching opposite result from that in Shepherd; held that the classification found in the “two counsel rule” is based not on potential punishment but on gravity of offense). In summary, courts faced with questions of this nature have attempted to conduct an inquiry into the legislative intent which impelled the enactment of procedural statutes applicable to “capital” crimes. The government, addressing its argument to this line of inquiry, has attempted to show that section 3281 was enacted to provide an unlimited time period for the return of indictments charging the commission of serious crimes. It argues, essentially, that the language “punishable by death,” which appears in section 3281, should be viewed, in light of Furman, as a shorthand reference to a category of offenses which are particularly grave in nature.

Counsel for both defendant and the government have represented to the Court that they have conducted research in an attempt to ascertain the legislative history of section 3281 and section 794. They have further represented to the Court that their search has revealed nothing which would assist the Court in its present endeavor, that is, to determine the legislative intent which provided the impetus for enactment of section 3281. At least one other court has conducted such an inquiry with a similar result. The court in United States v. Provenzano, 423 F.Supp. 662 (S.D.N.Y. 1976), aff'd 556 F.2d 562 (2d Cir. 1977), was faced with the issue of continued applicability vel non of section 3281 to the federal kidnapping statute, 18 U.S.C. § 1201, after United States v. Jackson, 390 U.S. 570, 88 S.Ct.

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Bluebook (online)
521 F. Supp. 1246, 1981 U.S. Dist. LEXIS 14511, Counsel Stack Legal Research, https://law.counselstack.com/opinion/united-states-v-helmich-flmd-1981.