USA v. Burke, et al.

District Court, D. New Hampshire·Decided January 4, 1999·No. CR-96-050-M·Published

Opinion

USA v. Burke, et al. CR-96-050-M 01/04/99 UNITED STATES DISTRICT COURT

DISTRICT OF NEW HAMPSHIRE

United States of America, Plaintiff

v. Criminal No. 96-50-1-6-M

John P. Burke, Stephen G. Burke, Matthew McDonald, Patrick J. McGonagle, Michael K. O'Halloran, and Anthony M. Shea, Defendants

O R D E R

Defendants Stephen G. Burke, Matthew McDonald, Patrick J.

McGonagle, Michael K. O'Halloran, and Anthony M. Shea (the "defendants") have filed a number of motions seeking, under Fed. R. Crim. P. 33, a new trial based on newly discovered evidence or, in the alternative, discovery relating to an alleged deal between the government and former codefendant John Burke regarding the lather's testimony at trial. For the reasons that follow, the defendants motions are denied.

Background

The defendants were charged under a fifteen count Second Superseding Indictment with numerous illegal activities including bank robbery, conspiracy to commit robbery, and carjacking. During trial, defendant John P. Burke entered into a plea agreement with the government under which he agreed to plead guilty to Count 4 of the Second Superseding Indictment (conspiracy to commit robbery) in exchange for the government's

dropping all remaining counts. The prosecution presented John Burke's plea agreement, to the court (and later to the jury), as a "naked" plea, that is, a straightforward plea to one count in exchange for dismissal of the remaining counts, without any further obligations on either side. John Burke's plea was accepted and accordingly, he was found guilty of Count 4. Sometime thereafter Burke also agreed to testify against his codefendants, pursuant to a grant of immunity extended by the government.

On December 22, 1997, the jury returned guilty verdicts against each defendant. Several months later, on July 1, 1998, the government moved, pursuant to Fed. R. Crim. P. 48(a), for leave to dismiss the one remaining count against John Burke, to which he previously had pled guilty.

On July 13, 1998, defendant Stephen Burke (John Burke's brother and co-defendant) filed a Second Motion for New Trial, based on newly discovered evidence. Defendants Shea and McGonagle filed similar motions and they and the remaining defendants moved to join some or all of their codefendants' similar motions. This order will resolve all outstanding motions for new trial as if constituting a single motion joined by all defendants.

While defendants' motions for new trial, based on, inter alia, John Burke's alleged deal, were pending, and following hearings, the government reconsidered its position and decided to withdraw its motion for leave to dismiss the remaining count

against John Burke. The motion to withdraw was granted on August 27, 1998, and John Burke was subseguently sentenced on the count to which he pled guilty.

Discussion

Fed. R. Crim. P. 33 provides that the court "may grant a new trial to [a] defendant if reguired in the interest of justice." In order to prevail on their motions for new trial based on newly discovered evidence, defendants must show that "the evidence was: (i) unknown or unavailable at the time of trial, (ii) despite due diligence, (ill) material, and (iv) likely to result in an acguittal upon retrial." United States v. Tibolt, 72 F.3d 965, 971 (1st Cir. 1995), cert. denied, 518 U.S. 1020 (1996). The third and fourth reguirements are less rigorous where, as defendants allege here, the newly discovered evidence was in the possession of, but not disclosed by the government. Id. In that case the test, as usually stated, is that "the nondisclosure justifies a new trial if it is 'material, ' . . . [that is,] if there is 'a reasonable probability' that the evidence would have changed the result . . . . [A] 'reasonable probability' is 'a probability sufficient to undermine confidence in the outcome.'" United States v. Sepulveda, 15 F.3d 1216, 1220 (1st Cir. 1993)(guoting United States v. Bagiev, 473 U.S. 667, 682 (1985)).

Defendants argue that John Burke and the government had either an explicit or implicit deal, or at least some actual understanding, under the terms of which John Burke would testify

against his codefendants in exchange for some benefit from the government. That "benefit" included the possibility of outright dismissal of the count pending against him to which he had already pled guilty. Defendants assert that this deal was unknown to them until the government filed its motion, after trial, for leave to dismiss the entire indictment against John Burke. They also contend that notice of the existence of this deal was withheld from them contrary to the mandate of Brady v. Maryland, 373 U.S. 83 (1963), and its progeny. Had they known of the actual arrangement, defendants argue, they could have effectively, or more effectively, impeached John Burke's credibility before the jury. Because John Burke provided powerful incriminating testimony, it was critical that any possible motivation for exaggeration or outright lying be put before the jury.

The government, on the other hand, asserts that there was no explicit or implicit deal with John Burke, and no sub rosa understanding, and, therefore, there is no "newly discovered evidence." This is so, the government argues, because the United States Attorney for the District of New Hampshire steadfastly refused to commit to do anything specific for John Burke in exchange for Burke's agreement to testify in the case beyond extending immunity. Rather, the prosecution says it took the position that it would agree to no deal in exchange for Burke's testimony — but, if Burke did testify voluntarily and told the truth (in the government's judgment) then the prosecution would

consider doing something for Burke — likely recommending leniency at sentencing on the count of conviction (Burke had been adjudicated guilty upon acceptance by the court of his earlier plea) but neither agreeing to nor foreclosing any possible benefit. Thus, the government argues, John Burke's position was no better than, and no different from that of any witness pending sentencing and voluntarily cooperating with the government without an agreement: he had a hope or reasonable expectation that his truthful testimony might win him favorable treatment, perhaps a favorable recommendation on sentence and a shorter prison term, maybe more — a hope or expectation obvious to everyone, including defense counsel, and one defense counsel thoroughly explored on cross-examination. Likewise, the government says, it too was in the same position it is always in when evaluating any witness's voluntary cooperation and testimony: it could make or withhold a favorable sentencing recommendation as it chose, and it could even dismiss all pending charges.1 Since the possibility of outright dismissal by the prosecutor is inherent in every case, the government continues, there was nothing about John Burke's situation that was either unknown to the defendants, or that had to be disclosed, and,

1 Although the court expressed its doubt and disagreement at hearings held on the motion for leave to dismiss all charges against John Burke, the government took the position that for all practical purposes it holds virtually unreviewable power to dismiss criminal charges (even after a guilty plea and an adjudication of guilt) in its discretion, and that the reguirement that it first obtain leave of court is little more than a formality, assuming the absence of bribery or similar fundamental corruptions of the court's processes.

accordingly, there can be no "newly discovered evidence" regarding Burke's situation warranting a new trial for these defendants.

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Related

Brady v. Maryland
373 U.S. 83 (Supreme Court, 1963)
United States v. Bagley
473 U.S. 667 (Supreme Court, 1985)
United States v. Sepulveda
15 F.3d 1216 (First Circuit, 1993)
United States v. Hahn
17 F.3d 502 (First Circuit, 1994)
United States v. Tibolt
72 F.3d 965 (First Circuit, 1995)
United States v. Sonya Evette Singleton
144 F.3d 1343 (Tenth Circuit, 1998)