United States v. Kastner

CourtDistrict Court, District of Columbia
DecidedJune 28, 2023
DocketCriminal No. 2021-0725
StatusPublished

This text of United States v. Kastner (United States v. Kastner) 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. Kastner, (D.D.C. 2023).

Opinion

UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA

UNITED STATES OF AMERICA,

v. Criminal Action No. 21-725 (RDM) JARED SAMUEL KASTNER,

Defendant.

MEMORANDUM OPINION AND ORDER

Defendant Jared Kastner appeals Magistrate Judge Upadhyaya’s order denying his

motion to lift the pretrial release condition prohibiting him from possessing a firearm. See Dkt.

97; Dkt. 100. The appeal presents the latest in a long string of attempts by Kastner to remove or

circumvent that condition of his pretrial release. For the reasons explained below, Kastner’s

appeal is DISMISSED as untimely.

I. BACKGROUND

This is one of the many cases pending before the Court relating to the attack on the U.S.

Capitol on January 6, 2021. Kastner is charged with four misdemeanor counts: (1) knowingly

entering or remaining in a restricted building or grounds without lawful authority, in violation of

18 U.S.C. § 1752(a)(1); (2) disorderly or disruptive conduct in a restricted building or grounds,

in violation of 18 U.S.C. § 1752(a)(2); (3) disorderly conduct in a Capitol building or grounds, in

violation of 40 U.S.C. § 5104(e)(2)(D); and (4) parading, demonstrating, or picketing in a

Capitol building, in violation of 40 U.S.C. § 5104(e)(2)(G). See Dkt. 24 (Superseding

Information). The Court has previously detailed Kastner’s alleged activities, see, e.g., Dkt. 42, but, for present purposes, the Court focuses on the history of his efforts to modify the condition

of his pretrial release restricting his access to firearms.

On December 14, 2021, Kastner had his initial appearance before Magistrate Judge Zia

Faruqui. Min. Entry (Dec. 14, 2021). At that hearing, Kastner requested a modification to the

standard pretrial release condition restricting firearm possession on the ground that he

volunteered as a security guard at his church. Judge Faruqui granted Kastner’s request and

modified the standard condition to permit him to possess a firearm “while on the premises of the

Wilmington Baptist Church” but only if (1) the “firearm [wa]s to be stored and secured on the

Church’s premises;” (2) Kastner was “prohibited from taking the firearms off the Church’s

grounds;” and (3) Kastner was otherwise “prohibited from possessing firearms.” Dkt. 11 at 3.

Kastner then twice moved this Court to lift the remaining firearm restrictions, first on

January 21, 2022, and again on April 13, 2022. Dkt. 20; Dkt. 37. The Court denied both

requests. Dkt. 35; Dkt. 42. In denying Kastner’s first request, the Court noted the importance of

protecting the safety of Pretrial Services officers who may need to visit Kastner on pretrial

release without warning. Dkt. 35 at 2-3. As D.C. Pretrial Services represented to the Court,

“permitting Defendant to keep firearms at his residence poses an unreasonable risk to the officers

who may need to conduct a home visit.” Id. The Court also focused on officer safety in denying

Kastner’s second request. Dkt. 42 at 9-10.

Neither of those decisions invoked a blanket ban on the possession of firearms by those

charged with non-violent misdemeanors. Rather, as the Court explained in its first decision

denying Kastner’s motion to modify Judge Faruqui’s order:

To start, the Court notes that the Magistrate Judge struck a reasonable balance in this case. Defendant is not categorically barred from possessing firearms, and he may continue to serve on the security detail for his Church. It is exceedingly unlikely that Defendant’s Pretrial Services officer will need

2 to visit Defendant while he is at church, and thus, that exception makes sense. Moreover, although Defendant is charged with misdemeanors, he stands accused of being among the first people to breach the U.S. Capitol on January 6, 2021, allegedly entering the building within five minutes of the “initial breach” and reaching the Crypt, “where he was confronted by a line of law enforcement officers.” Dkt. 22 at 3. And, although Defendant is not charged with committing a violent crime, he allegedly remained unlawfully in the Capitol building while rioters screamed and pushed against law enforcement. Id. The government further alleges that Defendant, during his trip to the Washington region in the days leading up to January 6, researched “Large Capacity Magazines in Virginia” and “concealed carry magazine limit [W]ashington DC,” id. at 6, suggesting that he owns a weapon equipped with a large capacity magazine and that he brought the weapon with him to the Washington region (most likely, Maryland and Virginia) in the days leading up to the assault on the Capitol. Even crediting Defendant’s suggestion that his Internet searches merely show that he was trying to comply with the law, the evidence that he hoped, if lawful, to bring a weapon equipped with a large capacity magazine to the rally-turned-riot is concerning. The Court accordingly concludes that, in this context, the temporary firearm restriction is . . . reasonably [necessary] to assure the safety of the Pretrial Services officers during Defendant’s supervision.

Second, the Court is unpersuaded that the firearm restriction represents a failure to treat Defendant “individually,” as Defendant contends. To the contrary, although the government asked the Magistrate Judge to impose an absolute restriction on Defendant’s possession of firearms, the Magistrate Judge, upon learning that Defendant serves as a security officer at his Church, rejected that request and, instead, allowed Defendant to carry a gun three times weekly while serving in the security detail at his Church. Dkt. 22 at 8. That exception to the restriction was granted in recognition of Defendant’s unique circumstances and his desire to continue serving his Church. Defendant’s suggestion that the Court has held that a firearms restriction should be imposed in every case is also incorrect. Rather, the Court merely concludes that, on the facts of this case, a partial restriction is appropriate and that the Magistrate Judge’s decision was reasonably tailored to Defendant’s circumstances.

Dkt. 35 at 3-4.

In denying Kastner’s second motion for reconsideration, the Court reiterated that it

“‘has [not] held that a firearms restriction should be imposed in every case’” and that “[t]here

may be context-dependent reasons for permitting defendants on pretrial release to possess

firearms at home, such as a desire to protect children while parenting alone, combined with a

3 determination that home visits need not be required, as was the case in United States v. Logsdon,

No. 22-cr-23 (D.D.C. 2022).” Dkt. 42 at 9 (quoting Dkt. 35 at 4; citing Dkt. 37 at 3-4). But,

here, on the “‘facts of this case,’” the Court reaffirmed that Kastner failed to show that there was

good reason to modify the “‘partial restriction’” that Judge Faruqui put in place. Id. (quoting

Dkt. 35 at 4) (emphasis in original). In short, the Court remained persuaded that permitting

Kastner to possess firearms in his home while on pretrial release would pose a risk to officer

safety and that he lacked any compelling, countervailing need to possess a firearm (outside of his

church) while on pretrial release. Id. at 9-10.

Despite this history, Kastner was undeterred.

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Related

District of Columbia v. Heller
554 U.S. 570 (Supreme Court, 2008)
United States v. Ferguson
574 F. Supp. 2d 111 (District of Columbia, 2008)

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United States v. Kastner, Counsel Stack Legal Research, https://law.counselstack.com/opinion/united-states-v-kastner-dcd-2023.