United States v. Sepulveda

57 F. Supp. 3d 627, 2014 U.S. Dist. LEXIS 158172, 2014 WL 5747286
CourtDistrict Court, E.D. Pennsylvania
DecidedNovember 6, 2014
DocketCase No. 1:13-cr-00310-GBL-1
StatusPublished

This text of 57 F. Supp. 3d 627 (United States v. Sepulveda) is published on Counsel Stack Legal Research, covering District Court, E.D. Pennsylvania primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
United States v. Sepulveda, 57 F. Supp. 3d 627, 2014 U.S. Dist. LEXIS 158172, 2014 WL 5747286 (E.D. Pa. 2014).

Opinion

MEMORANDUM OPINION AND ORDER

GERALD BRUCE LEE, District Judge.

THIS MATTER is before the Court on Defendant’s Motion to Narrow Count Four to Comply with the Grand Jury Clause (“Defendant’s Motion to Narrow Count Four”) (Doc. 118.) This case arises from the murder of DEA Special Agent in Bogota, Colombia on June 20, 2013. The issue before the Court is whether Count 4 of the indictment comports with the Grand Jury Clause of the Fifth Amendment. The Court DENIES Defendant’s Motion to Narrow Count Four to Comply with the Grand Jury Clause because the Government properly charged the two alternative offenses in the statute in the conjunctive [628]*628under United States v. Whitfield, 695 F.3d 288 (4th Cir.2012), and United States v. Vann, 660 F.3d 771 (4th Cir.2011).

I. BACKGROUND

On July 18, 2013, a federal grand jury returned an indictment charging six defendants with the murder of DEA Special Agent James Terry Watson. (Doc. 15 ¶ 1.) The murder allegedly occurred on June 20, 2013, in Bogota, Colombia in a taxi cab as part of a scheme to rob taxi riders. (Doc. 15 ¶ 17.) The indictment charged the six defendants, including Defendant Sepulve-da, with: Count 1, murder of an internationally protected person and aiding and abetting that murder, in violation of 18 U.S.C. §§ 2, 1116(a), (c); Count 3, conspiracy to kidnap an internationally protected person, in violation of 18 U.S.C. § 1201(c); and Count 4, kidnapping an internationally protected person and aiding and abetting that kidnapping, in violation of 18 U.S.C. §§ 2,1201. (Doc. 15.)

II. DISCUSSION

The Court DENIES Defendant’s Motion to Narrow Count Four because the Government correctly charged the two alternative offenses in the statute in the conjunctive. The Grand Jury Clause of the Fifth Amendment provides that “[n]o person shall be held to answer for a capital, or otherwise infamous crime, unless on presentment or indictment of a Grand Jury....” U.S. Const. Amend. V. The right to have a case presented to a grand jury prior to being tried or convicted of a felony is inviolable unless it is waived by the accused. See Stirone v. United States, 361 U.S. 212, 215-16, 80 S.Ct. 270, 4 L.Ed.2d 252 (1960).

Courts have found that a defendant’s grand jury rights were violated when a court (1) improperly instructed a jury in a manner that allowed them to convict the defendant on charges that had not been presented to the grand jury, or (2) improperly convicted a defendant to the entirety of a conjunctive count, rather than a specific portion. See United States v. Vann, 660 F.3d 771, 774-76 (4th Cir.2011) (citing Omari v. Gonzales, 419 F.3d 303, 308 n. 10 (5th Cir.2005); United States v. Rhynes, 206 F.3d 349, 379-81 (4th Cir.1999)). The legal analysis in those cases, however, turned on errors at the sentencing stage, not the charging phase.

In both Whitfield and Vann, the Fourth Circuit analyzed indictments which alleged conjunctively elements that are disjunctive in the underlying statute. In both cases the court held that charging, in a single count, alternative, offenses contained in a statute in the conjunctive is proper. See United States v. Whitfield, 695 F.3d 288 (4th Cir.2012) (suggesting that the grand jury clause was implicated at sentencing); United States v. Vann, 660 F.3d 771 (4th Cir.2011).

In Whitfield, the defendant was charged with violating 18 U.S.C. § 2113(e), a statute including multiple disjunctive components.1 695 F.3d at 307. “The government alleged two of the three alternative offenses in the conjunctive in a single count—including a conjunctive of the attempt and the completed offense—and did not include the third alternative offense available under the statute.” (Doc. 161 at [629]*6295.) In reversing the defendant’s conviction, the court explained:

[T]he [two alternative offenses] were properly charged with all of their essential elements and, thus, there was no defect in the Count Four allegations. The error arose not from the indictment ... but from the district court’s instructions on an element of an uncharged offense ... on which Whitfield was ultimately convicted and sentenced.

Whitfield, 695 F.3d at 308 (citing United States v. Higgs, 353 F.3d 281, 306 (4th Cir.2003)).

In Vann, the defendant contested sentences where the defendant’s convictions arose from guilty pleas to conjunctively drawn indictments tracking the language of two subsections of the North Carolina indecent liberties statute.2 See N.C. Gen. Stat. § 14-202.1(a); Vann, 660 F.3d at 774. In analyzing whether Vann’s convictions were proper the court stressed that “it is settled that a charging document must allege conjunctively the disjunctive components of an underlying statute.” Vann, 660 F.3d at 774 (citations omitted).

The Court holds that Count 4 of the indictment is properly charged because it does not violate the Fifth Amendment’s Grand Jury Clause. Count 4 (kidnapping; aiding and abetting) alleges, in pertinent part, as follows:

The allegations set forth in paragraphs 1 through 17 of this Indictment are incorporated herein by reference.... On or about June 20, 2013, in Bogota, Colombia ... Edwin Gerardo Figueroa Se-pulveda ... aiding and abetting ... others, did, and did attempt to, unlawfully seize, confine, inveigle, decoy, kidnap and abduct Special Agent Watson, an internationally protected person and an official and employee of the United States engaged in his official duties.”

(Doc. 15 at 9) (emphasis added). Additionally, 18 U.S.C. § 1201 provides, in pertinent part, that “[wjhoever unlawfully seizes, confines, inveigles, decoys, kidnaps, abducts, or carries away and holds for ransom or reward or otherwise any person ... when ... the person is ... an internationally protected person” is subject to “imprisonment for any term of years or for life and, if the death of any person results, shall be punished by death or life imprisonment.” 18 U.S.C. § 1201(a)(4) (emphasis added). The statute further provides that, “Whoever attempts

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Related

Omari v. Gonzales
419 F.3d 303 (Fifth Circuit, 2005)
Stirone v. United States
361 U.S. 212 (Supreme Court, 1960)
United States v. Vann
660 F.3d 771 (Fourth Circuit, 2011)
United States v. Dustin John Higgs
353 F.3d 281 (Fourth Circuit, 2003)
United States v. Larry Whitfield
695 F.3d 288 (Fourth Circuit, 2012)
United States v. Rhynes
206 F.3d 349 (Fourth Circuit, 1999)

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Bluebook (online)
57 F. Supp. 3d 627, 2014 U.S. Dist. LEXIS 158172, 2014 WL 5747286, Counsel Stack Legal Research, https://law.counselstack.com/opinion/united-states-v-sepulveda-paed-2014.