United States v. Jessie Jones, Jr.

65 F.3d 520, 1995 U.S. App. LEXIS 26174, 1995 WL 548159
CourtCourt of Appeals for the Sixth Circuit
DecidedSeptember 18, 1995
Docket94-5913
StatusPublished
Cited by14 cases

This text of 65 F.3d 520 (United States v. Jessie Jones, Jr.) is published on Counsel Stack Legal Research, covering Court of Appeals for the Sixth Circuit primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
United States v. Jessie Jones, Jr., 65 F.3d 520, 1995 U.S. App. LEXIS 26174, 1995 WL 548159 (6th Cir. 1995).

Opinions

JONES, J., delivered the opinion of the court. RYAN, J. (p. 524), delivered a separate concurring opinion. MATIA, D.J. (pp. 524-526), delivered a separate dissenting opinion.

NATHANIEL R. JONES, Circuit Judge.

Defendant-Appellant Jessie Jones, Jr., appeals his conviction and sentence for possession of a firearm by a felon, and this court must determine whether the lower court committed plain error by instructing the jury that an essential element of the crime had been proven. This court’s previous holdings make it clear that “the trial judge invades the jury’s province when, instead of simply instructing on the law, he applies the law to facts he has determined.” United States v. Mentz, 840 F.2d 315, 319 (6th Cir.1988). Accordingly, we vacate the judgment of the lower court and remand this case for further proceedings.

I.

On January 24, 1994, Jones was indicted for being a felon in possession of a firearm in violation of 18 U.S.C. § 922(g) (1988). Jones subsequently pleaded not guilty, and a jury trial was conducted from April 25-27, 1994. At the close of the government’s case, Jones and the government stipulated that Jones was a convicted felon. Jones’ Br. at 4; see J.A. at 14. During the presentation of the defense’s evidence, Jones testified on his own behalf and, once again, admitted that he had been convicted of a felony. J.A. at 14.

Following the close of all evidence, the district court gave the following jury instruction with respect to the essential element of Jones’s prior conviction:

The first element you must find beyond a reasonable doubt before you can convict the defendant is that the defendant had been convicted of a felony in a court of the United States or any state prior to the date he is charged with possessing a firearm. To satisfy the first element, you need only find that the defendant was, in fact, convicted of a felony, and that the conviction was prior to the receipt or possession of the firearm charged in this case. Defendant admits that he was convicted of a felony prior to the date alleged in the indictment, so this element of the offense has been proven. Since defendant admits that he was previously convicted of a felony, you will find that the government has established this element of the offense, and you will proceed to determine if the government has proven the remaining elements of the offense.

J.A. at 23-24. Defense counsel raised no objection to this instruction, and Jones was subsequently convicted and sentenced to 300 months imprisonment followed by three months supervised release.

II.

On appeal, Jones argues that, although he failed to object at trial, it was plain error for the court to instruct the jury that an essential element of the crime had been proven. Where a party fails to object to jury instructions at trial, the court of appeals will not address the question on appeal unless the error is obvious and prejudicial, in which ease, the court will consider it in the interest of justice. Young v. Langley, 793 F.2d 792, 795 (6th Cir.), cert. denied, 479 U.S. 950, 107 S.Ct. 436, 93 L.Ed.2d 385 (1986). In such a case, the court of appeals may review only for clear and prejudicial error. Chonich v. Wayne County Community College, 973 F.2d [522]*5221271, 1275 (6th Cir.1992) (amended opinion); see also United States v. Prujansky, 415 F.2d 1045, 1048 (6th Cir.1969) (holding that court should review for plain error where defendant failed to object to instruction at trial); Fed.R.Crim.P. 52(b).

III.

Jones’s argument is simple: by instructing the jury that an essential element of the crime had been proven, the district court improperly invaded the province of the jury. The government argues, however, that Jones’s argument is unavailing because he stipulated to the facts that the judge directed the jury to find. The government relies heavily upon this court’s holding in Prujan-sky, where this court stated:

We understand the general rule in a criminal case is that the court may not direct a verdict of guilty no matter how strong the evidence and that the Government must prove every essential element of the crime beyond a reasonable doubt. It is a better practice for a trial judge to charge on all elements of the alleged crime unless the parties otherwise stipulate.

415 F.2d at 1048 (citation omitted) (emphasis added). The government argues, moreover, that in the eases cited by Jones, the defendants had not stipulated to the elements for which the trial judge instructed. See Mentz, 840 F.2d at 318 (whether bank was FDIC insured); United States v. Piche, 981 F.2d 706, 716 (4th Cir.1992) (whether establishment was place of public accommodation), cert. denied, — U.S.-, 113 S.Ct. 2356, 124 L.Ed.2d 264 (1993); Hoover v. Garfield Heights Mun. Ct., 802 F.2d 168, 177 (6th Cir.1986) (whether a lawful arrest had occurred), cert. denied, 480 U.S. 949, 107 S.Ct. 1610, 94 L.Ed.2d 796 (1987); United States v. White Horse, 807 F.2d 1426, 1429 (8th Cir.1986) (whether the Telephone Authority was an Indian tribal organization under 18 U.S.C. § 1163).

The government’s position, however, ignores two points. First, Mentz and other appellate and Supreme Court cases, which are dispositive of this issue, were decided after this court’s decision in Prujansky. Second, the delegation of fact finding powers to juries under our Constitution is not conditioned upon the evidence being contested; nor is the government’s burden to prove every element of the offense relieved by a defendant’s tactical decision not to contest an essential element. See Estelle v. McGuire, 502 U.S. 62, 69-70, 112 S.Ct. 475, 481, 116 L.Ed.2d 385 (1991).

In United States v. Mentz, a bank robbery case, the district court instructed the jury that two banks were insured by the Federal Deposit Insurance Corporation at the time of the alleged robbery. The insured status of the bank was, however, an essential element of the offense. In reversing the Mentz’s conviction, this court found that the instruction “relieved the government of establishing, and the jury from finding beyond a reasonable doubt, every essential element of [the crime].” Mentz, 840 F.2d at 320.

“The Sixth Amendment to the Constitution guarantees to a defendant the opportunity for a jury to decide guilt or innocence.” Id. at 319 (citing Duncan v. Louisiana,

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Bluebook (online)
65 F.3d 520, 1995 U.S. App. LEXIS 26174, 1995 WL 548159, Counsel Stack Legal Research, https://law.counselstack.com/opinion/united-states-v-jessie-jones-jr-ca6-1995.