United States v. Manglitz

939 F. Supp. 1211, 1996 U.S. Dist. LEXIS 13844, 1996 WL 534799
CourtDistrict Court, D. Maryland
DecidedAugust 27, 1996
DocketCrim. No. S-95-0314
StatusPublished

This text of 939 F. Supp. 1211 (United States v. Manglitz) is published on Counsel Stack Legal Research, covering District Court, D. Maryland primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
United States v. Manglitz, 939 F. Supp. 1211, 1996 U.S. Dist. LEXIS 13844, 1996 WL 534799 (D. Md. 1996).

Opinion

MEMORANDUM AND ORDER

MALETZ, Judge, Sitting by Designation.

On June 29, 1996, a jury convicted the defendant, Philip Manglitz of one count of conspiracy with the intent to distribute marijuana in violation of 21 U.S.C. § 846, one count of conspiracy to engage in monetary transactions in property derived from specified unlawful activity in violation of 18 U.S.C. § 1956(h) and four counts of engaging in monetary transactions in property derived from specified unlawful activity in violation of 18 U.S.C. § 1957. The jury acquitted the defendant of possession with the intent to distribute marijuana in violation of 21 U.S.C. § 841 and could not reach a verdict on two additional counts charging violations of 18 U.S.C. § 1957. Following his conviction, the defendant timely filed a motion for an expansion of time to file a motion for a new trial under Rule 33 of the Federal Rules of Criminal Procedure and timely filed his Rule 33 motion within the expanded time period set by the court. For the reasons set forth below, the motion for new trial will be denied.

The defendant bases his motion for new trial on claims of prosecutorial misconduct during the course of the trial. The defendant claims that the prosecution violated his rights in four manners: (1) the introduction and improper use of prior bad acts in violation of Federal Rule of Evidence 404(b); (2) the distortion and misstatement of critical facts during the prosecution’s closing argument; (3) improper comment upon the defendant’s failure to testily; and (4) failure of the prosecution to provide discovery required under Brady v. Maryland, 373 U.S. 83, 83 S.Ct. 1194, 10 L.Ed.2d 215 (1963). In assessing claims of prosecutorial misconduct, the Fourth Circuit has instructed,

The test for reversible prosecutorial misconduct generally has two components: that (1) the prosecutor’s remarks or conduct must in fact have been improper, and (2) such remarks or conduct must have prejudicially affected the defendant’s substantial rights so as to deprive the defendant of a fair trial.

United States v. Mitchell, 1 F.3d 235, 240 (4th Cir.1993) (citations omitted).

The defendant’s first claim is that the government violated Rule 404(b) by (1) introducing evidence that the defendant had discussed with Dana Kleberg, a cooperating co-defendant, his own previous drug dealing, (2) using the term “bank fraud” during the redirect examination of Ronald Carter, another cooperating co-defendant, (3) proffering tax evasion as a motive for the defendant’s alleged criminal activity and (4) alleging that the defendant had engaged in obstruction of justice both previously when he paid James Lee to “keep quiet” about Mr. Manglitz’s role in his prior drug dealing during Mr. Lee’s incarceration and contemporaneously when he disposed of cash in his home. None of these four allegations, separately or taken together, meet the burden set forth in Mitchell in order to make a new trial appropriate.

One of the most hotly contested elements during the defendant’s trial was his knowledge that the funds he was receiving from Dana Kleberg and Randolph Ayersman were the proceeds of specified illegal activity, to wit, marijuana distribution. To that end, prior to the beginning of the trial, the court held that the government would not be precluded from introducing evidence through Mr. Kleberg and Mr. Ayersman that the [1214]*1214defendant had told each of them he had previously been engaged in the distribution of marijuana. The court held that the government would be precluded from introducing detailed testimony about the nature or extent of the defendant’s prior drug dealing, in order to avoid undue delay or unnecessary prejudice to the defendant. The court had previously ruled that the government would be precluded from introducing tapes where the defendant discussed his prior arrest for the possession with the intent to distribute fifty pounds of marijuana in Laredo, Texas, because the “risk that the jury will be excited to irrational behavior by such specific evidence of Mr. Manglitz’s past drug trafficking activities is disproportionate to the probative value of such evidence.” United States v. Manglitz, No. S-95-0314, slip opinion at p. 10 (D.Md. Jan. 25,1996).

At trial, the government introduced evidence that during a flight from Acapulco to the United States, Mr. Manglitz discussed his prior drug dealing with Mr. Kleberg. When Mr. Kleberg testified that Mr. Man-glitz admitted that he had been “arrested down on the Texas-Mexiean border,” the court sustained an objection by the defense, ordered the testimony stricken from the record and cautioned “you are very close.” It was not improper for the government to introduce evidence that Mr. Manglitz brought up his knowledge of the methods and means of drug dealing in order to prove that he had knowledge that the money he was obtaining from Mr. Kleberg was the proceeds of marijuana trafficking. The government erred when it introduced testimony about Mr. Manglitz’s arrest, but the eourt took great pains to prevent any unfair prejudice to the defendant from any mention of his previous arrest, by striking the testimony and giving an immediate cautionary instruction to the jury. These actions were sufficient to dissipate the harm to the defendant. Richardson v. Marsh, 481 U.S. 200, 210, 107 S.Ct. 1702, 1709, 95 L.Ed.2d 176 (1987) (“ju-ríes are presumed to follow their instructions”).

The defendant’s next claim is that he was prejudiced by the government’s introduction of the term “bank fraud” during the re-direct examination of Ronald Carter. Mr. Carter testified on direct examination that he had not signed some of the deeds which bore his name. On cross-examination, he testified that the defendant had removed himself as a partner in Carman Associates, the entity which owned the properties sold to Mr. Kle-berg and Mr. Ayersman, during 1991. On re-direct examination, the government introduced through.Mr. Carter documents signed by the defendant during 1991 which identified him as a general partner in Carman Associates. At this point, the government asked whether Mr. Carter was familiar with the term “bank fraud,” After Mr. Carter indicated that he was, the government did not further develop this line of questions.

The reference to “bank fraud” does not fall within the purview of Rule 404(b), because the “bank fraud” referred to occurred during and as a part of the charged money laundering.1

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Brady v. Maryland
373 U.S. 83 (Supreme Court, 1963)
Griffin v. California
380 U.S. 609 (Supreme Court, 1965)
Anderson v. United States
417 U.S. 211 (Supreme Court, 1974)
United States v. Frady
456 U.S. 152 (Supreme Court, 1982)
United States v. Young
470 U.S. 1 (Supreme Court, 1985)
Richardson v. Marsh
481 U.S. 200 (Supreme Court, 1987)
United States v. Robinson
485 U.S. 25 (Supreme Court, 1988)
United States v. William N. Anderson
481 F.2d 685 (Fourth Circuit, 1973)
United States v. Raynard Carroll
678 F.2d 1208 (Fourth Circuit, 1982)
United States v. Rosalba Solivan
937 F.2d 1146 (Sixth Circuit, 1991)
United States v. Paul Michael Mitchell
1 F.3d 235 (Fourth Circuit, 1993)
United States v. Gerald Wiedyk
71 F.3d 602 (Sixth Circuit, 1996)
United States v. Hassan Francis
82 F.3d 77 (Fourth Circuit, 1996)
Griffin v. California
380 U.S. 609 (Supreme Court, 1965)
United States v. Kennedy
32 F.3d 876 (Fourth Circuit, 1994)
United States v. Porter
821 F.2d 968 (Fourth Circuit, 1987)

Cite This Page — Counsel Stack

Bluebook (online)
939 F. Supp. 1211, 1996 U.S. Dist. LEXIS 13844, 1996 WL 534799, Counsel Stack Legal Research, https://law.counselstack.com/opinion/united-states-v-manglitz-mdd-1996.