United States v. St Cyr

CourtDistrict Court, District of Columbia
DecidedOctober 20, 2023
DocketCriminal No. 2022-0185
StatusPublished

This text of United States v. St Cyr (United States v. St Cyr) is published on Counsel Stack Legal Research, covering District Court, District of Columbia primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
United States v. St Cyr, (D.D.C. 2023).

Opinion

UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA

UNITED STATES OF AMERICA,

v. Criminal Action No. 22-185 (JDB) YVONNE ST CYR, Defendant.

MEMORANDUM OPINION & ORDER

Before the Court is defendant Yvonne St Cyr’s motion for release pending appeal. For the

reasons explained below, the Court will deny the motion.

Background

St Cyr was convicted by a jury on six counts related to her participation in the breach of

the United States Capitol on January 6, 2021: civil disorder and aiding and abetting, in violation

of 18 U.S.C. §§ 231(a)(3) and 2 (Counts One and Two); entering and remaining in a restricted

building or grounds, in violation of 18 U.S.C. § 1752(a)(1) (Count Three); disorderly and

disruptive conduct in a restricted building or grounds, in violation of 18 U.S.C. § 1752(a)(2)

(Count Four); disorderly conduct in a Capitol Building, in violation of 40 U.S.C. § 5104(e)(2)(D)

(Count Five); and parading, demonstrating, or picketing in a Capitol Building, in violation of 40

U.S.C. § 5104(e)(2)(G) (Count Six). See Judgment [ECF No. 119] at 1–2. Prior to trial, St Cyr

filed a motion for a change of venue, arguing that she would not receive a fair trial in the District

of Columbia. Mot. for Transfer of Venue [ECF No. 50] (“Venue Mot.”). The Court denied her

motion. Mem. Op. & Order [ECF No. 63] (“Venue Order”) at 6, 10.

On September 13, 2023, the Court sentenced St Cyr to 30 months’ imprisonment and three

years of supervised release. Judgment at 3–4. The Court permitted St Cyr to remain released on

1 bond and to voluntarily surrender to the Bureau of Prisons at a date to be determined by the United

States Probation Office. See id. at 3. St Cyr’s reporting date is now October 24, 2023. Mot. for

Extension of Time to Self-Surrender [ECF No. 126] (“Extension Mot.”) at 1.

St Cyr filed a notice of appeal on September 25, 2023. Two days later, she filed a motion

asking the Court to release her during the pendency of her appeal and stay her sentence of

imprisonment. Mot. for Release Pending Appeal [ECF No. 124] (“Mot.”). On October 9, 2023,

the government filed a response in opposition. U.S.’s Opp’n to Mot. [ECF No. 125] (“Gov’t

Opp’n”). The motion is now ripe for decision.

Analysis

A court “shall order” that a defendant

who has been found guilty of an offense and sentenced to a term of imprisonment, and who has filed an appeal or a petition for a writ of certiorari, be detained, unless the judicial officer finds—

(A) by clear and convincing evidence that the person is not likely to flee or pose a danger to the safety of any other person or the community if released under section 3142(b) or (c) of this title; and

(B) that the appeal is not for the purpose of delay and raises a substantial question of law or fact likely to result in—

(i) reversal,

(ii) an order for a new trial,

(iii) a sentence that does not include a term of imprisonment, or

(iv) a reduced sentence to a term of imprisonment less than the total of the time already served plus the expected duration of the appeal process.

18 U.S.C. § 3143(b)(1). “If the judicial officer makes such findings, such judicial officer shall

order the release of the person . . . .” Id. Where, as here, a defendant is not a flight risk or a danger

2 to the community,1 courts use a two-step inquiry to determine whether to release that defendant

pending appeal under § 3143(b)(1): “(1) Does the appeal raise a substantial question? (2) If so,

would the resolution of that question in the defendant’s favor be likely to lead to reversal [or one

of the other outcomes enumerated in § 3143(b)(1)(B)(ii)–(iv)]?” United States v. Perholtz, 836

F.2d 554, 555 (D.C. Cir. 1987). “[A] substantial question is a close question or one that very well

could be decided the other way.” Id. (internal quotation marks omitted). “[A] presumption of

valid conviction” governs this inquiry. Id. at 556. “[T]he defendant bears the burden of rebutting

this presumption and ‘demonstrat[ing] that he has a substantial question to present [upon appeal]

before he may be [released pending appeal].’” United States v. Libby, 498 F. Supp. 2d 1, 3 (D.D.C.

2007) (quoting United States v. Shoffner, 791 F.2d 586, 589 (7th Cir. 1986)).

St Cyr argues that her appeal “presents a substantial question of law likely to result in [an]

order [for] a new trial” because her jury pool was both presumptively and actually biased, and

accordingly this Court erred in denying her change-of-venue motion. Mot. at 5; see id. at 5–8.

But St Cyr’s motion, devoid of supporting caselaw, falls well short of demonstrating the “close

question” that might warrant her release pending appeal.

I. Presumption of Prejudice

St Cyr first contends that this Court erred in denying her change-of-venue motion because

her jury pool was presumptively biased. Mot. at 6. A presumption of jury prejudice arises only in

an “extreme case,” Skilling v. United States, 561 U.S. 358, 381 (2010), “when the population in

the original district is ‘so aroused against the defendant and so unlikely to be able objectively to

judge the defendant’s guilt or innocence on the basis of the evidence presented at trial that his due

1 The Court previously concluded that St. Cyr was not a danger or a flight risk when it authorized her release pending trial and incarceration. The government does not argue otherwise in its opposition. See Mot. at 5; Gov’t Opp’n (omitting any discussion of this prong).

3 process rights will be violated’ if the case is not transferred,” United States v. Sheppard, Crim. A.

No. 21-203 (JDB), 2022 WL 17978837, at *6 (D.D.C. Dec. 28, 2022) (quoting United States v.

Haldeman, 559 F.2d 31, 60–62 (D.C. Cir. 1976) (en banc) (per curiam)) (cleaned up). In

determining whether a presumption of prejudice arises, courts consider “(1) the size and

characteristics of the jury pool; (2) the type of information included in the media coverage; and (3)

the time period between the arrest and trial, as it relates to the attenuation of the media coverage.”

Id. (internal quotation marks omitted).

Courts in this District, including this Court, have considered these factors as they relate to

the January 6 cases and have unanimously held that these are not “extreme case[s]” warranting

mandatory transfer. See, e.g., Sheppard, 2022 WL 17978837, at *6–7; United States v. Brock, 628

F. Supp. 3d 85, 94–98 (D.D.C. 2022); United States v. Nassif, 628 F. Supp. 3d 169, 187–88

(D.D.C. 2022); United States v. Rhodes, 610 F. Supp. 3d 29, 57–59 (D.D.C. 2022); United States

v. Bochene, 579 F. Supp. 3d 177, 181–82 (D.D.C.

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

Related

Skilling v. United States
561 U.S. 358 (Supreme Court, 2010)
United States v. Glen Shoffner
791 F.2d 586 (Seventh Circuit, 1986)
United States v. Quiles-Olivo
684 F.3d 177 (First Circuit, 2012)
United States v. Libby
498 F. Supp. 2d 1 (District of Columbia, 2007)
In Re: Tsarnaev v.
780 F.3d 14 (First Circuit, 2015)
United States v. Haldeman
559 F.2d 31 (D.C. Circuit, 1976)

Cite This Page — Counsel Stack

Bluebook (online)
United States v. St Cyr, Counsel Stack Legal Research, https://law.counselstack.com/opinion/united-states-v-st-cyr-dcd-2023.