United States v. Riley Ray Fultz

602 F.2d 830, 1979 U.S. App. LEXIS 12816, 4 Fed. R. Serv. 747
CourtCourt of Appeals for the Eighth Circuit
DecidedJuly 31, 1979
Docket79-1208
StatusPublished
Cited by5 cases

This text of 602 F.2d 830 (United States v. Riley Ray Fultz) is published on Counsel Stack Legal Research, covering Court of Appeals for the Eighth 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. Riley Ray Fultz, 602 F.2d 830, 1979 U.S. App. LEXIS 12816, 4 Fed. R. Serv. 747 (8th Cir. 1979).

Opinion

GIBSON, Chief Judge.

Riley Ray Fultz appeals his conviction of charges arising from the robbery of the Breton National Bank of South Des Moines in Des Moines, Iowa, on May 19, 1978. On July 25,1978, a federal grand jury returned a two-count indictment against Fultz. Count I charged violation of 18 U.S.C. §§ 2 and 2113(d). 1 Count II charged him with conspiring with Curtis Gale Doby and John Stanley Campbell to rob the bank in violation of 18 U.S.C. § 371. 2 The indictments against Fultz and Campbell were consolidated for trial, and Doby was tried separately. 3 After trial, a jury returned a guilty verdict on both counts against Fultz on November 16, 1978. On February 28, 1979, Chief Judge Stuart sentenced Fultz to a term of imprisonment for twenty-five years on the first count, and for a period of five years on Count II, the terms to run concurrently.

On appeal, Fultz urges three grounds for reversal of his conviction: defective indictment; misconduct on the part of law enforcement officials; and introduction of improper testimony before the jury. We find the errors, if any, do not warrant reversal and affirm his conviction.

I. The Indictment

Appellant asserts that a mistake contained in Count I of the indictment created sufficient confusion to deny him effective assistance of counsel as well as procedural due process because it did not suffi *832 ciently apprise him of the crux of the offense with which he was charged to enable him to formulate a proper defense. Count I of the indictment first charges Riley Ray Fultz with regular bank robbery in terms of the statutory language of 18 U.S.C. § 2113(a). 4 Then it lists Curtis Gale Doby as having put in jeopardy the life of a bank teller by means and use of a dangerous weapon while committing the robbery. 5 This latter charge constitutes aggravated bank robbery in violation of 18 U.S.C. § 2113(d). 6

It appears that the Government in drafting the indictment inadvertently substituted the name of Curtis Gale Doby when it intended to use Fultz’s name. The District Court recognized that the Government had not intended to charge the crime in the manner in which it appears in the indictment, but indicated that it would hold the Government to proof of the indictment in the form in which it was drafted. The court concluded that Count I could properly be read as charging that Fultz, during the commission of the robbery, had aided and abetted Curtis Gale Doby in assaulting a bank employee with a dangerous weapon. All three of the bank robbers were armed. The court found that the Government had presented sufficient evidence on this charge to submit it to the jury. 7 The jury found him guilty.

The United States Supreme Court, in Hamling v. United States, 418 U.S. 87, 117, 94 S.Ct. 2887, 2907, 41 L.Ed.2d 590 (1974), stated:

Our prior cases indicate that an indictment is sufficient if it, first, contains the elements of the offense charged and fairly informs a defendant of the charge against which he must defend, and, second, enables him to plead acquittal or conviction in bar of future prosecutions for the same offense. Hagner v. United States, 285 U.S. 427, 52 S.Ct. 417, 76 L.Ed. 861 (1932); United States v. Debrow, 346 U.S. 374, 74 S.Ct. 113, 98 L.Ed. 92 (1953).

See also United States v. Starr, 584 F.2d 235, 237 (8th Cir. 1978), cert. denied, 439 U.S. 1115, 99 S.Ct. 1019, 59 L.Ed.2d 73 (1979); United States v. Brown, 540 F.2d 364, 371 (8th Cir. 1976); Tasby v. United States, 504 F.2d 332, 335 (8th Cir. 1974), cert. denied, 419 U.S. 1125, 95 S.Ct. 811, 42 L.Ed.2d 826 (1975).

We agree with the District Court that Count I of the indictment sufficiently apprised the defendant of the charges against him to enable him to prepare his defense. The indictment clearly set forth all of the essential elements of a violation of 18 U.S.C. § 2113(d) in terms of the statutory language. The substitution of the name of *833 Curtis Gale Doby merely indicated that Fultz had not actually performed the actions constituting the aggravation portion of the robbery, but did assist and abet in that aggravation. The language of the indictment indicated that the grand jury considered Riley Ray Fultz responsible for the commission of the actions constituting the aggravation portion of the robbery. This logical reading of the language and the citation to the aiding and abetting statute, 18 U.S.C. § 2, was sufficient to apprise Fultz of the charge of violation of 18 U.S.C. § 2113(d) against which he had to defend. As this court stated in United States v. Garrison, 527 F.2d 998, 999 (8th Cir. 1975); “[I]t is not necessary that an indictment state how and in what manner the defendant aided and abetted another in the commission of an offense against the United States.” And an aider and abetter may be held liable as a principal. 18 U.S.C. § 2. See also United States v. Harris, 523 F.2d 172, 174 (6th Cir. 1975). The trial transcript indicates that Fultz was not unfairly surprised at the evidence that he was called upon to meet.

Count I of the indictment is also sufficient to enable Fultz to plead his conviction as a bar to future prosecutions for the same offense.

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

Related

Government of the Virgin Islands v. Smith
45 V.I. 293 (Supreme Court of The Virgin Islands, 2003)
United States v. Pritchett
31 M.J. 213 (United States Court of Military Appeals, 1990)
United States v. Michael Drape
753 F.2d 660 (Eighth Circuit, 1985)

Cite This Page — Counsel Stack

Bluebook (online)
602 F.2d 830, 1979 U.S. App. LEXIS 12816, 4 Fed. R. Serv. 747, Counsel Stack Legal Research, https://law.counselstack.com/opinion/united-states-v-riley-ray-fultz-ca8-1979.