United States v. Mieses-Casiano

161 F. Supp. 3d 166, 2016 U.S. Dist. LEXIS 19228, 2016 WL 634069
CourtDistrict Court, D. Puerto Rico
DecidedFebruary 17, 2016
DocketCRIMINAL NO. 16-028 (PAD)
StatusPublished

This text of 161 F. Supp. 3d 166 (United States v. Mieses-Casiano) is published on Counsel Stack Legal Research, covering District Court, D. Puerto Rico primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
United States v. Mieses-Casiano, 161 F. Supp. 3d 166, 2016 U.S. Dist. LEXIS 19228, 2016 WL 634069 (prd 2016).

Opinion

MEMORANDUM AND ORDER

Delgado-Hernández, District Judge.

Before the court is the “United States’ Motion Requesting a Revocation of the Magistrate Judge’s Release Order and an Order of Detention Pending Trial” (Docket No. 21). For the reasons explained below, defendant shall be detained without bail pending trial.

I. BACKGROUND

On January 20, 2016, the defendant was charged with knowingly possessing a firearm (a Gloek pistol, model 22, .40 caliber, bearing serial number NBR6640), modified to shoot more than one round of ammunition, without manual reloading, by a single function of the trigger, in violation of 18 U.S.C. 922(o )(1) and 924(a)(2) (Docket No. 9).

On-January 22, 2016, U.S. Magistrate Judge Bruce J. McGiverin presided over the arraignment detention hearing, during which the United States moved for defendant’s detention (Docket Nos. 14 and 20 at pp. 3-4). At the conclusion of the hearing, the Magistrate Judge denied the government’s request, setting the following conditions of release: bail in the amount of $10,000 (with only $3,000 secured); a third-party custodian; drug testing; home detention with electronic monitoring; plus other standard conditions (Docket No. 14).

The same day, the government filed an emergency motion requesting a stay of the Magistrate Judge’s order, and a de novo bail hearing (Docket No. 13). The court granted the government’s motion, stayed defendant’s release pending de novo review, and scheduled a de novo bail hearing (Docket No. 15). The hearing was held on February 2, 2016 (Docket No. 22). The parties argued their positions. The government proceeded via proffer. Defendant presented the transcript of the hearing held before the Magistrate Judge, and the testimony of defendant’s mother. Id. Based on the information received during the hearing, the court ordered that defendant remain under custody pending further review of testimony and evidence.

II. STANDARD OF REVIEW

The Bail Reform Act of 1984, 18 U.S.C. §§ 3141-3156, permits detention of a defendant pending trial if no condition or combination of conditions will reasonably assure the appearance of the person as required or the safety of any other person and the community. 18 U.S.C. §§ 3142(b) and (e). The government must establish risk of flight by a preponderance of the evidence; and/or dangerousness by clear and convincing evidence. United States v. Mercedes, 254 F.3d 433, 436 (2d Cir.2001); United States v. Gebro, 948 F.2d 1118, 1121 (9th Cir.1991).

Where probable cause is found to believe that a defendant has committed a crime listed or in the circumstances set forth in 18 U.S.C. § 3142(e), a rebuttable presumption arises that no conditions or combination of conditions exist that will reasonably assure the appearance of the defendant and the safety of the community. A grand jury indictment on a covered offense is enough to demonstrate probable cause for purposes of triggering the presumption. United States v. Vargas, 804 [168]*168F.2d 157, 163 (1st Cir.1986); United States v. Holland, 922 F.Supp.2d 70, 71 (D.D.C. 2013).

Once triggered, the presumption imposes on the defendant a burden of production. United States v. O’Brien, 895 F.2d 810, 814-815 (1st Cir.1990). The burden is not heavy. United States v. Stone, 608 F.3d 939, 946 (6th Cir.2010). It is satisfied introducing at least some evidence contrary to the facts presumed. Id. Rebuttal evidence does not burst or destroy the presumption, which does not disappear, maintaining evidentiary weight. United States v. Dillon, 938 F.2d 1412, 1416 (1st Cir.1991); O’Brien, 895 F.2d at 814-815. The government retains the burden of persuasion throughout, in both presumption and non-presumption eases. Stone, 608 F.3d at 946; Bess, 678 F.Supp. 929 at 932. Review of a magistrate judge’s release order is de novo. United States v. Tortora, 922 F.2d 880, 883 n. 4 (1st Cir.1990). The court must state in writing the reasons for the action taken. United States v. Moss, 887 F.2d 333, 338 (1st Cir.1989); O’Brien, 895 F.2d at 813.

III. DISCUSSION

A. Initial Inquiry

The statutory presumption does not apply here. Defendant is charged with the knowing possession of a machine gun. The offense is not listed in 18 U.S.C. §§ 3142(e)(2) and (3), as an offense to which the detention presumption applies.1 [169]*169Nevertheless, the statute authorizes pretrial detention in eases that involve a felony that is not otherwise a crime of violence that involves the possession or use of a firearm or destructive device (as those terms are defined in Section 921), or any other dangerous weapon. 18 U.S.C. § 3142(f)(1)(E). Additionally, detention is authorized where there is a serious risk that the person will flee. 18 U.S.C; § 3142(f)(2)(A).

The government seeks detention on those grounds, clarifying that rather than risk of flight, defendant poses a risk of non-appearance (Docket No. 21 at p. 5). In making a detention determination, the court must consider the nature and circumstances of the offense charged, the weight of the evidence against the defendant, the history and characteristics of the defendant, and the nature and seriousness of the danger to any other person or the community that would be posed by the defendant’s release. 18 U.S.C. § 3142(g).

B. Detention Factors

1.Nature and Circumstances of Offense

Defendant possessed a .40 caliber machine gun loaded with 22 rounds of live ammunition, and an additional high-capacity magazine loaded with 21 rounds of ammunition in a public area (a public sidewalk). The weapon qualifies as a firearm or destructive device (as those terms are defined in Section 921), or as a dangerous weapon under 18 U.S.C. § 3142(f)(1)(E); If convicted, defendant faces up to 10 years of imprisonment. The offense charged, the circumstances of the crime, and the statutory exposure underpinning it favor detention.2

2. Weight of Evidence

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Related

United States v. Stone
608 F.3d 939 (Sixth Circuit, 2010)
United States v. Juan Vargas
804 F.2d 157 (First Circuit, 1986)
United States v. Frank O. Moss
887 F.2d 333 (First Circuit, 1989)
United States v. Edward O'Brien
895 F.2d 810 (First Circuit, 1990)
United States v. Carmen A. Tortora
922 F.2d 880 (First Circuit, 1990)
United States v. John M. Dillon
938 F.2d 1412 (First Circuit, 1991)
United States v. Wayne Patrick Gebro
948 F.2d 1118 (Ninth Circuit, 1991)
United States v. Bess
678 F. Supp. 929 (District of Columbia, 1988)
United States v. Gray
529 F. Supp. 2d 177 (D. Massachusetts, 2007)
United States v. Torres-Rosario
600 F. Supp. 2d 327 (D. Puerto Rico, 2009)
United States v. Holland
922 F. Supp. 2d 70 (District of Columbia, 2013)
United States v. Mercedes
254 F.3d 433 (Second Circuit, 2001)

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Bluebook (online)
161 F. Supp. 3d 166, 2016 U.S. Dist. LEXIS 19228, 2016 WL 634069, Counsel Stack Legal Research, https://law.counselstack.com/opinion/united-states-v-mieses-casiano-prd-2016.