United States v. Joseph Russell Mikalajunas, Jr.

936 F.2d 153
CourtCourt of Appeals for the Fourth Circuit
DecidedJune 11, 1991
Docket90-5684
StatusPublished
Cited by32 cases

This text of 936 F.2d 153 (United States v. Joseph Russell Mikalajunas, Jr.) is published on Counsel Stack Legal Research, covering Court of Appeals for the Fourth 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. Joseph Russell Mikalajunas, Jr., 936 F.2d 153 (4th Cir. 1991).

Opinions

RESTANI, Judge:

Defendant Joseph R. Mikalajunas, Jr. appeals a sentence imposed under the Federal Sentencing Guidelines in the United States District Court for the District of Maryland. Mr. Mikalajunas pleaded guilty to a charge of accessory after the fact to second degree murder. He alleges that the sentence he received was improper because the court erred in finding a two level enhancement to the offense calculation based on restraint of the victim. We conclude that the appeal is well taken and reverse and remand for resentencing.

BACKGROUND

On August 22, 1989, Michael Mikalaju-nas, the brother of appellant Joseph R. Mikalajunas, Jr., was indicted by a grand jury in the District of Maryland for the murder of Christopher Weathers.

On January 16, 1990, a superseding indictment was filed charging Michael Mika-lajunas, Craig E. Largent and William R. Woolridge with murder. That superseding indictment also charged that Joseph R. Mi-kalajunas, Jr. was an accessory after the fact to first degree murder and second degree murder.

On April 4, 1990, Joseph Mikalajunas appeared before the district court and pleaded guilty to the charge of accessory after the fact to second degree murder. That plea was made pursuant to an agreement in which the government and the defense reached a nonbinding stipulation that an offense level of twenty-six was the appropriate guideline level. On July 2, 1990, Joseph Mikalajunas was sentenced to fifty-seven months incarceration. That is the minimum sentence in offense level twenty-five, which the district court concluded was the appropriate level.

According to the statement of facts offered in support of the guilty plea, Joseph Mikalajunas (“Joseph” or “Defendant”) was home on leave from the army and was asleep in his parents’ home in Anne Arun-del County, Maryland, when his brother Michael woke him and told him that Christopher Weathers had been killed earlier that morning. Immediately thereafter, Michael took Joseph to see the body. Joseph observed that the victim had been stabbed, noting one large wound in the neck. Michael explained that he, Craig Largent and William Woolridge, Jr. had lured Weathers to a secluded spot on Fort George G. Meade. Michael indicated that Woolridge had struck Weathers in the head with a baseball bat, after which Weathers had attempted to flee. Michael and Largent had [155]*155then chased and caught Weathers and stabbed him to death.

Several days later, Joseph telephoned Steven Bonney1 and convinced him to assist Michael in burying the body. Several weeks after the murder, Bonney, Michael and another individual buried the body. Subsequently, the third individual who had assisted in the burial led police to the body.

According to the sworn affidavit of Detective Dirk A. Rinehart, Joseph told detectives that Michael had told him that he had “held Mr. Weathers while stabbing him, and that [Michael] had inflicted the wounds_” Appendix at 43. In apparent contravention of the plea agreement, in which the government promised not to use against Joseph information that he supplied after he agreed to cooperate, the government used this affidavit to support its sentencing recommendation.

On May 25, 1990, the Probation Department filed a presentence report. The report stated that the underlying offense of second degree murder has a base level of thirty-three and an accessory after the fact charge warrants an offense level six levels lower than the underlying offense, resulting in a base offense level of twenty-seven. The report allowed an adjustment for acceptance of responsibility and deducted two points, yielding a total offense level of twenty-five.

Following the government’s objection to the computation in the presentence report the Probation Department filed an addendum to the presentence report in which it took issue with the government’s attempt to obtain an upward departure under Guideline § 5K2.8 (Extreme Conduct), as well as the government’s attempt to obtain an increase in the base offense level for “restraint of victim,” pursuant to Guideline § 3A1.3. The court rejected the section 5K2.8 upward adjustment, but it raised the offense level by two, pursuant to Guideline § 3A1.3. Because of a downward departure of two levels for substantial assistance to law enforcement the court arrived at a final offense level of twenty-five.

DISCUSSION

I. Affidavit Used in Contravention of Plea Agreement

In apparent contravention of the plea agreement, the government used the affidavit of Detective Rinehart to support its contention that an upward adjustment for physical restraint was warranted. According to the affidavit, Joseph told police that Michael had related that he had held Weathers while stabbing him. The government had agreed not to use information, such as the affidavit, which was obtained from Joseph while he cooperated. The statement submitted in support of the plea simply said that Michael had told Joseph that he and one other person had caught Weathers and stabbed him. Joseph’s attorney failed to object at sentencing to use of the Rinehart affidavit, but argues now that the government breached the agreement, and the sentence, which was based on the affidavit, should be reversed.

Whether objection was waived need not be resolved, because there is no relevant distinction between the facts agreed to for sentencing purposes and the affidavit.2 Without further elucidation, there is no meaningful way to distinguish between one, catching someone and stabbing him, and two, holding someone and stabbing him. If the government had other information indicating that some substantial restraint was employed, there is nothing of record to show that such information was imparted to Joseph or that such information was properly before the court for purposes of the sentencing.

II. Enhancement for Physical Restraint of the Victim

At issue before us is whether Guideline § 3A1.3, providing for enhancement of [156]*156offense level for physical restraint, requires something beyond acts which are part and parcel of a stabbing. According to the Commentary to Guideline § 1B1.1, physical restraint is “the forcible restraint of the victim such as by being tied, bound, or locked up.” The concept of restraint is not limited to these examples. The question presented is whether the conduct involved here falls with the concept illustrated by these examples, and is intended to be covered by Guideline § 3A1.3.

The leading Fourth Circuit case on enhancement for physical restraint is United States v. Stokley, 881 F.2d 114 (4th Cir.1989). In that case, the defendant placed explosives in a room and prevented the victim from leaving. The bomb went off, injuring both. The court enhanced the offense level by two points for physical restraint of the victim. Stokley is distinguishable from the facts at bar. First, the victim was confined to a room for some time. Second, detonation of explosives does not in and of itself involve physical restraint. Most bombing victims do not know of their imminent fate. It adds something to the offense that the victim had an apprehension of the expected blast and could do nothing about it because of the physical restraint. Stabbing, however, is of a different nature. The very act of stabbing normally will involve some physical restraint.

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Bluebook (online)
936 F.2d 153, Counsel Stack Legal Research, https://law.counselstack.com/opinion/united-states-v-joseph-russell-mikalajunas-jr-ca4-1991.