United States v. Van Avermaet

CourtDistrict Court, District of Columbia
DecidedJanuary 25, 2024
DocketCriminal No. 2021-0443
StatusPublished

This text of United States v. Van Avermaet (United States v. Van Avermaet) 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. Van Avermaet, (D.D.C. 2024).

Opinion

UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA

UNITED STATES OF AMERICA,

v. Criminal No. 21-cr-443-4 (TSC/ZMF) JEAN PAUL VAN AVERMAET,

Defendant.

MEMORANDUM OPINION

The government charged Jean Paul Van Avermaet and three co-defendants with

conspiracy to rig bids and fix prices for contracts involving security services. Indictment ¶ 16,

ECF No. 1. The United States solicited bids and entered into contracts with Defendants for

security services on United States military bases in Belgium. Id. ¶ 19. The single-count

Indictment charges Van Avermaet with violating the Sherman Act between 2019 and 2020 by

conspiring to fix prices for contracts with the United States through the Department of Defense

(“DoD”) and with the North Atlantic Treaty Organization (“NATO”), a multilateral military

alliance funded in part by the United States. Id. ¶ 16; 15 U.S.C. § 1. The objective of the

conspiracy was to win and receive payments for DoD and NATO security contracts at non-

competitive, inflated prices. Indictment ¶ 17.

According to the Indictment, Van Avermaet is a resident and citizen of Belgium, and

from 2010 to 2020 served as CEO of G4S Secure Solutions, a Belgian company also alleged to

have played a role in the conspiracy. Indictment ¶¶ 6–7. Van Avermaet is alleged to have

arranged a “coordination breakfast meeting” between the heads of two of G4S’s competitors and

co-conspirators in September 2019. Id. ¶¶ 4, 11, 18(a). The government more broadly alleges

Page 1 of 16 his participation in the conspiracy through his role as CEO of G4S. Gov’t’s Consol. Opp’n to

Mots. to Dismiss at 7, ECF No. 48.

Van Avermaet moved to dismiss for lack of jurisdiction the portion of the single-count

Indictment related to the NATO contracts and the portion of the Indictment related to the DoD

contracts for failure to state an offense. Mot. to Dismiss NATO Portion of Count One, ECF No.

42 (“NATO MTD”); Mot. to Dismiss DoD Portion of Count One, ECF No. 43 (“DoD MTD”).

If granted, the motions would dispose of the entire Indictment. The court referred the matter to

Magistrate Judge Zia M. Faruqui for full case management up to and including issuance of a

Report and Recommendation on any dispositive motions. January 26, 2023 Minute Order.

Magistrate Judge Faruqui entered a Report and Recommendation (“R&R”) on June 2, 2023,

recommending that the court DENY both motions. R&R, ECF No. 56. Defendant objected to

the R&R, the government responded to the objections, and Defendant submitted a reply. Objs.

to R&R, ECF No. 57 (“Objections”); Gov’t’s Opp’n to Objs. to R&R, ECF No. 60 (“Opp’n to

Objections”); Reply ISO Objs. to R&R, ECF No. 61 (“Reply ISO Objections”).

The court, while modifying the reasoning, accepts Magistrate Judge Faruqui’s ultimate

recommendation with respect to the NATO motion to dismiss, and adopts the R&R with respect

to the DoD motion to dismiss. Consequently, for the reasons set forth below, the court will

DENY Van Avermaet’s NATO and DoD motions to dismiss.

I. LEGAL STANDARD

The Federal Magistrates Act lists eight pretrial motions, including motions to dismiss or

quash an indictment, for which Magistrate Judges may provide “proposed findings of fact and

recommendations for the disposition [of the matter].” 28 U.S.C. § 636(b)(1)(B); see Baylor v.

Mitchell Rubenstein & Assocs., P.C., 857 F.3d 939, 945 (D.C. Cir. 2017). Recommendations are

reviewed de novo by a district court judge. 28 U.S.C. § 636(b)(1)(C); see also Fed. R. Crim. P. Page 2 of 16 59(b). The district court judge may accept, reject, or modify the recommendation, receive

further evidence, or resubmit the matter to the magistrate judge with instructions. Fed. R. Crim.

P. 59(b)(3).

Title 18, section 3231 of the United States Code gives U.S. district courts original

jurisdiction over “all offenses against the laws of the United States.” 18 U.S.C. § 3231. “[I]f an

indictment or information alleges the violation of a crime set out in Title 18 or in one of the other

statutes defining federal crimes, that is the end of the jurisdictional inquiry.” United States v.

Fahnbulleh, 752 F.3d 470, 476 (D.C. Cir. 2014). If the Indictment states a violation of the

Sherman Act, 15 U.S.C. § 1, “[n]o more is necessary to establish subject matter jurisdiction.” Id.

“A motion that the court lacks jurisdiction may be made at any time while the case is pending.”

Fed. R. Crim. P. 12(b)(2).

The Foreign Trade Antitrust Improvements Act of 1982 (“FTAIA”) “excludes from the

Sherman Act’s reach much anticompetitive conduct that causes only foreign injury.”

F. Hoffmann-La Roche Ltd. v. Empagran S.A., 542 U.S. 155, 158 (2004). “It does so by setting

forth a general rule stating that the Sherman Act ‘shall not apply to conduct involving trade or

commerce . . . with foreign nations.’” Id. (quoting 15 U.S.C. § 6a). The FTAIA creates

exceptions to the general rule where the charged “conduct has a direct, substantial, and

reasonably foreseeable effect” on U.S. domestic commerce. 15 U.S.C. § 6a(1)(A). In this

Circuit, the FTAIA applies as a jurisdictional limit on the Sherman Act’s reach. Empagran S.A.

v. F. Hoffman-LaRoche, Ltd., 315 F.3d 338, 341 (D.C. Cir. 2003) (Empagran I), vacated sub

nom. F. Hoffmann-La Roche Ltd. v. Empagran S.A., 542 U.S. 155 (2004) (Empagran II) (“[W]e

believe that our holding regarding the jurisdictional reach of FTAIA is faithful to the language of

the statute.”); see also Empagran S.A. v. F. Hoffmann-LaRoche, Ltd., 417 F.3d 1267, 1269 (D.C.

Page 3 of 16 Cir. 2005) (Empagran III) (concluding that “we are without subject matter jurisdiction under the

FTAIA.”).

A criminal defendant may also move to dismiss based on a “defect in the indictment,”

such as a “failure to state an offense.” Fed. R. Crim. P. 12(b)(3)(B)(v). “In ruling on a motion to

dismiss for failure to state an offense, a district court is limited to reviewing the face of the

indictment and, more specifically, the language used to charge the crimes.” United States v.

Sunia, 643 F. Supp. 2d 51, 60 (D.D.C.

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