United States v. Mitchell Leon Farkas

CourtCourt of Appeals for the Sixth Circuit
DecidedDecember 1, 2023
Docket22-6061
StatusUnpublished

This text of United States v. Mitchell Leon Farkas (United States v. Mitchell Leon Farkas) is published on Counsel Stack Legal Research, covering Court of Appeals for the Sixth 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. Mitchell Leon Farkas, (6th Cir. 2023).

Opinion

NOT RECOMMENDED FOR PUBLICATION File Name: 23a0492n.06

Case No. 22-6061

UNITED STATES COURT OF APPEALS FOR THE SIXTH CIRCUIT

FILED Dec 01, 2023 ) UNITED STATES OF AMERICA, KELLY L. STEPHENS, Clerk ) Plaintiff-Appellee, ) ) ON APPEAL FROM THE v. ) UNITED STATES DISTRICT ) COURT FOR THE EASTERN MITCHELL LEON FARKAS, ) DISTRICT OF KENTUCKY Defendant-Appellant. ) ) OPINION

Before: COLE, GILMAN, and LARSEN, Circuit Judges. The court issued a PER CURIAM opinion. LARSEN, J. (pp. 10–12), delivered a separate concurring opinion.

PER CURIAM. A jury convicted Mitchell Farkas of attempted murder, assault with a

dangerous weapon, and associated racketeering offenses based on Farkas’s role in a stabbing at a

federal prison conducted by members of the Aryan Circle. The district court sentenced Farkas to

thirty years’ imprisonment. Farkas argues that there was insufficient evidence to support his

convictions, that the jury should not have heard certain evidence, and that his sentence is in

violation of double jeopardy and procedurally unreasonable. For the following reasons, we affirm.

I.

In 2018, Mitchell Farkas and Jonathan Gober were incarcerated at the United States

Penitentiary Big Sandy, a high-security federal prison in Kentucky. Farkas and Gober were

members of the Aryan Circle, a gang active in the federal prison system. The Aryan Circle Case No. 22-6061, United States v. Farkas

required its members to carry out stabbings when ordered. The member would potentially become

the target if he did not execute the order.

A.S. was a prospective Aryan Circle member at USP Big Sandy. A.S. was “getting

investigated” by the Aryan Circle to determine if he would be “validated” as a full member. (Trial

Tr., R. 451, PageID 5058.) The Aryan Circle discovered that A.S. previously made a statement to

law enforcement and was therefore “no good,” “no longer Aryan Circle,” and “had to go.” (Id.)

Aryan Circle leadership assigned Farkas and Gober to attack A.S. While exercising at the

USP Big Sandy gymnasium, Gober suddenly grabbed A.S.’s legs. While Gober held A.S. down,

Farkas stabbed A.S. in the head repeatedly for approximately a minute. (Sentencing Hr’g Tr., R.

463, PageID 5286; Gov’t Ex. 31, Dkt.. 37, Video.) When A.S. attempted to break free, Farkas

yelled, “Get his legs.” (Trial Tr., R. 447, PageID 4113.) The attack was captured by surveillance

video. (Trial Tr., R. 451, PageID 4841; Gov’t Ex. 31, Dkt. 37, Video.) A.S. permanently lost

vision in his left eye as a result of the stabbing. After the attack, Gober gave a “rundown” of the

stabbing to his Aryan Circle superior, who relayed the report up the chain of command. (Trial Tr.,

R. 447. PageID 4155–56, 4158–59.)

At trial, A.S. identified Farkas as his assailant. Two prison officials identified Farkas based

on the surveillance video footage. A prison investigator testified that Farkas was discovered with

a “red unknown substance,” apparently blood, on his hands and clothes after the incident. (Trial

Tr., R. 447, PageID 4005–06.) A photograph of a “plastic homemade weapon” recovered near the

scene was displayed for the jury. (Id. at PageID 4064; Gov’t Ex. 29, Dkt. 37, p. 4.)

Robert Johnson, a lieutenant with the Bureau of Prisons, testified that he had investigated

prior attacks by Aryan Circle members, including a stabbing at USP Lewisburg in 2014 and

stabbings at USP Big Sandy in 2014, 2017, and 2019. (Trial Tr., R. 451, PageID 4834–35, 4837–

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38.) Robert Bodin, an agent with the Bureau of Alcohol, Tobacco, and Firearms, testified that he

had investigated an Aryan Circle related murder in Louisiana in 2016 and Aryan Circle stabbings

at USP Talladega in 2010, USP Pollack in 2014, and USP Big Sandy in 2014. (Trial Tr., R. 450,

PageID 4684, 4701–02, 4730–31.) Bodin clarified that Farkas was not involved in these incidents.

Johnson testified about how dangerous weapons can be made in prison. Over Farkas’s

objection, the district court admitted a photograph depicting weapons like the ones Johnson

described. (Gov’t Ex. 28, Dkt. 37, p. 3.) The court instructed the jury to consider the photograph

“only for the purpose of visualizing the testimony” and emphasized that “there’s no allegation that

any of these items have any connection to Mr. Farkas, [nor] that Mr. Farkas was in any way

associated with these particular weapons.” (Trial Tr., R. 450, PageID 4759–60.)

The jury convicted Farkas on four counts: (1) attempted murder in aid of racketeering under

18 U.S.C. § 1959(a)(5), (2) assault in aid of racketeering under 18 U.S.C. § 1959(a)(3), (3)

attempted murder under 18 U.S.C. § 1113, and (4) assault with a dangerous weapon with intent to

do bodily harm under 18 U.S.C. § 113(a)(3). The assault in aid of racketeering count was

dismissed prior to sentencing. The district court calculated Farkas’s offense level to be 39 under

the advisory Sentencing Guidelines, including a two-level enhancement for physical restraint of

the victim under § 3A1.3. This calculation resulted in a Guidelines range of 30 years to life, with

statutory maximums setting the upper bound at 40 years. An offense level of 37 would have led

to the same Guidelines range. The court sentenced Farkas to a combined 30 years’ imprisonment:

10 years for the attempted murder in aid of racketeering count, 20 years consecutive for attempted

murder under § 1113, and 10 years concurrent for assault with a dangerous weapon under

§ 113(a)(3). (Judgment, R. 420, PageID 2353–54.) The court sentenced Farkas at the low end of

-3- Case No. 22-6061, United States v. Farkas

the Guidelines range only to avoid disparity with co-defendants who pleaded guilty. (Sentencing

Hr’g Tr., R. 463, PageID 5322–23.)

II.

A.

Farkas argues that there is insufficient evidence to support his convictions. He contends

that the state failed to prove that he was the person who stabbed A.S., which was necessary for all

four counts. See 18 U.S.C. § 1959(a)(3, 5); 18 U.S.C. § 1113; 18 U.S.C. § 113(a)(3). He also

argues that the state failed to prove that he acted with the purpose of maintaining his position in

the Aryan Circle. Proof of this purpose is required for the racketeering convictions. United States

v. Hackett, 762 F.3d 493, 500 (6th Cir. 2014). Evidence is insufficient to prove an element if,

when viewed in the light most favorable to the prosecution, no rational juror would find guilt

beyond a reasonable doubt. Jackson v. Virginia, 443 U.S. 307, 317–19 (1979).

There is sufficient evidence that Farkas stabbed A.S. First, A.S. identified Farkas at trial

as the person who stabbed him.

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