United States v. Lee

CourtDistrict Court, District of Columbia
DecidedNovember 20, 2024
DocketCriminal No. 2023-0368
StatusPublished

This text of United States v. Lee (United States v. Lee) 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. Lee, (D.D.C. 2024).

Opinion

UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA

UNITED STATES OF AMERICA,

v. Case No. 1:23-cr-00368 (TNM) JUSTIN LEE,

Defendant.

MEMORANDUM ORDER

Defendant Justin Lee moves for a judgment of acquittal after his bench trial ended in

several guilty counts. For all counts, he insists that the Government did not meet its burden of

proof. He also takes issue with the Court’s legal conclusions on the elements of his offenses.

And he claims that his convictions for a few counts offend the First Amendment.

The Court will ratify its previous findings in all respects. Sufficient evidence supported a

guilty verdict for each of the charges. And Lee’s legal challenges to the elements lack merit, as

they have been considered and rejected already. More, the First Amendment has nothing to say

about his conviction. Accordingly, the Court denies Lee’s motion for acquittal.

I.

Along with thousands of others, Lee attended the Stop the Steal Rally at the White House

Ellipse on January 6, 2021. 1 Galvanized by the crowd’s fervor, Lee joined the raucous

procession from the Ellipse to the Capitol building. Lee and his compatriots approached the west

1 The following background section comes from the Court’s oral ruling, Tr. Bench Trial Proceedings III, ECF No. 52; witness testimony credited by the Court, see Tr. Bench Trial Proceedings III, 3:15–20 and generally Tr. Bench Trial Proceedings I, ECF No. 49; and government exhibits admitted at trial, see Gov. Exhibit List, ECF No. 46, and generally Tr. Bench Trial Proceedings I. front of the Capitol grounds, waving flags and sounding bullhorns, only to find that the area had

been closed. Two lines of snow fencing encased the property, and official “Area Closed” signs

dotted the lawn. But Lee and his fellow rioters were undeterred. With Lee’s encouragement and

assistance, the crowd scaled the barriers and flooded the restricted area. Lee even took an Area

Closed sign as a souvenir.

The protesters ultimately broke through one police line on the plaza, clearing their path to

the Lower West Terrace Tunnel. There, officers formed a human barrier to prevent the rioters

from entering the building. The crowd launched a violent assault on these officers, beating them

with baseball bats and other weapons. Lee joined in the attack, lobbing an ignited smoke bomb

into the enclosed, crowded space. The smoke bomb struck the shield of Metropolitan Police

Department (“MPD”) Officer Jason Sterling, causing him to lose his footing, and spewed

disorienting smoke through the tunnel. Sterling and his fellow officers struggled to see through

the haze.

But Lee was not done. He then threw three more objects at the police line as other rioters

continued to beat and berate the officers. And he pointed a flashlight into the dark tunnel,

turning it on and off in rapid succession to produce a dizzying strobe-like effect. The officers

released tear gas into the crowd, and Lee left the property.

Lee later was indicted on seven counts. Indictment, ECF No. 1. He waived his right to a

jury and proceeded to a bench trial. Waiver of Trial by Jury, ECF No. 11. After a two-day trial,

the Court found Lee guilty of five of the charges. Minute Entry 08/23/2024. As sentencing

loomed, Lee filed the present motion for acquittal. Def.’s Mot. Acquittal, ECF No. 48. The

Government opposed the motion. Gov. Opp’n Br., ECF No. 50. The motion is now ripe for

review.

2 II.

Following a guilty verdict, a defendant can move for a judgment of acquittal. Fed. R.

Crim. P. 29(c). This is a high hurdle to surmount. United States v. Hale-Cusanelli, 628 F. Supp.

3d 320, 324 (D.D.C. 2022). The verdict may be reversed “only if no reasonable [factfinder]

could accept the evidence as sufficient to support the conclusion of the defendant’s guilt beyond

a reasonable doubt.” United States v. Campbell, 702 F.2d 262, 264 (D.C. Cir. 1983). The Court

must “view the evidence in the light most favorable to the verdict” and “presume that the

[factfinder] has properly carried out its functions of evaluating the credibility of witnesses,

finding the facts, and drawing justifiable inferences.” Id. Essentially, a motion for judgment of

acquittal “succeeds only where the Government’s case is legally defective or has suffered a

significant failure of proof.” United States v. Cappuccio, 2023 WL 6975931, at *1 (D.D.C. Oct.

23, 2023).

III.

Lee objects to all five of his guilty charges, but for varying reasons. The Court addresses

Lee’s objections count-by-count.

A.

Start with Lee’s conviction for a civil disorder in violation of 18 U.S.C. § 231(a)(3). Lee

mounts two lines of attack here. First, he insists that the charge violates the First Amendment. 2

Alternatively, he asserts that the evidence could not sustain a guilty verdict. Neither contention

has merit.

2 Before trial, Lee argued that 18 U.S.C. § 231(a)(3) is facially unconstitutional. Mot. Dismiss Count, ECF No. 18. Now, he insists that it is unconstitutional as applied to him. Def.’s Mot. Acquittal 3–9.

3 To begin with, the civil disorder conviction does not infringe on Lee’s First Amendment

rights. Lee points out that the charge rests on his throwing of the smoke bomb at the officers.

Def.’s Mot. Acquittal at 3–4. But he claims that this act was expressive, as “he intended to

convey a particular message by tossing a small smoke bomb in the direction of [the] group of

police officers defending [the] tunnel.” Id. at 4. This message was allegedly one of “protest,” as

“he objected to the manner in which the police discharged their duties on January 6.” Id.

According to Lee, this valiant message “would have been understood by the persons who viewed

it.” Id.

The Court cannot agree. For conduct to qualify as protected speech, there must be both

“[a]n intent to convey a particularized message,” and a “great” likelihood “that the message

would be understood by those who viewed it.” Spence v. State of Wash., 418 U.S. 405, 411

(1974). Lee fails on both elements. As for the intent prong, the Court already found that Lee’s

“police protest” motivation was not credible. Tr. Bench Trial Proceedings III, 6:3–5 (“I do not

believe Mr. Lee’s claim that he was trying to make a statement about police brutality.”). The

Court stressed that “the officers in the tunnel were clearly in defensive mode,” as “[t]hey literally

had their backs to the wall and [were] being attacked by a large and violent crowd of rioters.”

Tr. Bench Trial Proceedings III, 6:7–11. So “[w]hile Mr. Lee may well have been irate or angry

at the officers for various reasons,” the Court thought “he was doing something very different

from just making his voice heard. He was aiding his fellow rioters and seeking to interfere with

the officers’ performance of their duties.” Tr. Bench Trial Proceedings III, 6:14–18. Viewing

the evidence in the light most favorable to the Government, this credibility determination was

rational. Lee joined in the mob after attending the Stop the Steal Rally. He flooded the property

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