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Punch and Jurists: April 22, 1997

Volume 4, Number 16

In this issue:

  1. U.S. v. Eidson, No. 94-2330 (11th Cir.) (108 F.3d 1336) (March 31, 1997) (Judge Phyllis A. Kravitch) (p None)
  2. U.S. v. Corona, No. 96-3-238 (5th Cir.) (108 F.3d 565) (March 12, 1997) (Judge Patrick E. Higginbotham) (p None)
  3. U.S. v. Booze, No. 96-3025 (D.C. Cir.) (108 F.3d 378) (March 18, 1997) (Judge Judith W. Rogers) (p None)
  4. U.S. v. McVeigh, No. 96-CR-68-M (D.Colo.) (954 F.Supp. 1441) (January 28, 1997) (Judge Richard P. Matsch) (p None)
  5. U.S. v. Morales, No. 94-10507 (9th Cir.) (108 F.3d 1031) (March 5, 1997) (Judge David R. Thompson) (p None)
  6. Singleton v. Norris, No. 95-3032 (8th Cir.) (108 F.3d 872) (March 12, 1997) (Judge Roger L. Wollman) (p None)
  7. Rashad v. Burt, No. 96-1040 (6th Cir.) (108 F.3d 677) (March 14, 1997) (Judge Boyce F. Jr. Martin) (p None)
  8. U.S. v. Contreras, No. 95-2070 (10th Cir.) (108 F.3d 1255) (March 11, 1997) (Judge Wade Brorby) (p None)
  9. Doe v. Weld, No. Civ. A. No. 96-11968-PBS (D.Mass.) (954 F.Supp. 425) (December 17, 1997) (Judge Patti B. Saris) (p None)
  10. U.S. v. Blackwell, No. Crim. No. 95-671 (AJL) (D.N.J.) (954 F.Supp. 944) (January 21, 1997) (Judge Alfred J. Jr. Lechner) (p None)
  11. U.S. v. Jerez, No. 95-1549 (7th Cir.) (108 F.3d 684) (February 27, 1997) (Judge Kenneth F. Ripple) (p None)
  12. U.S. v. Binford, No. 96-2419 (7th Cir.) (108 F.3d 723) (March 4, 1997) (Judge William J. Bauer) (p None)
  13. U.S. v. Bissell, No. Crim. A. No. 95-539 (AJL) (D.N.J.) (954 F.Supp. 841) (December 13, 1996) (Judge Alfred J. Jr. Lechner) (p None)
  14. U.S. v. Webster, No. 96-30159 (9th Cir.) (108 F.3d 1156) (March 12, 1997) (Judge Eugene A. Wright) (p None)
  15. U.S. v. Qualls, No. 95-50378 (9th Cir.) (108 F.3d 1019) (March 5, 1997) (Judge Robert R. Beezer) (p None)
  16. U.S. v. Jerez, No. 95-1549 (7th Cir.) (108 F.3d 684) (February 27, 1997) (Judge Kenneth F. Ripple) (p None)
  17. U.S. v. Brown, No. 96-1414 (8th Cir.) (108 F.3d 863) (March 11, 1997) (Judge David R. Hansen) (p None)
  18. U.S. v. Jones, No. 94-5913 (6th Cir.) (108 F.3d 668) (March 12, 1997) (Judge Alice M. Batchelder) (p None)
  19. In Re Sealed Case, No. 96-3036 (D.C. Cir.) (108 F.3d 372) (March 14, 1997) (Per Curiam) (p None)
  20. U.S. v. Gaydos, No. 95-3468 (3rd Cir.) (108 F.3d 505) (March 14, 1997) (Judge Richard L. Nygaard) (p None)
  21. U.S. v. Lowe, No. Cr. No. 95-10404-PBS (D.Mass.) (954 F.Supp. 401) (January 16, 1997) (Judge Patti B. Saris) (p None)
  22. U.S. v. Carraway, No. 94-`938 (7th Cir.) (108 F.3d 745) (March 5, 1997) (Per Curiam) (p None)
  23. U.S. v. Morales, No. 94-10507 (9th Cir.) (108 F.3d 1031) (March 5, 1997) (Judge David R. Thompson) (p None)
  24. U.S. v. Valdez-Torres, No. 96-3040 (D.C. Cir.) (108 F.3d 385) (March 18, 1997) (Judge Karen LeCraft Henderson) (p None)
  25. U.S. v. Perkins, No. 95-5698 (4th Cir.) (108 F.3d 512) (March 10, 1997) (Judge Donald S. Russell) (p None)
  26. U.S. v. Corona, No. 96-3-238 (5th Cir.) (108 F.3d 565) (March 12, 1997) (Judge Patrick E. Higginbotham) (p None)
  27. U.S. v. Griffiths, No. 2:95-CR-55-01 (D.Vt.) (954 F.Supp. 738) (January 11, 1997) (Judge William K. III Sessions) (p None)

U.S. v. Eidson, No. 94-2330 (11th Cir.) (108 F.3d 1336) (March 31, 1997) (Judge Phyllis A. Kravitch)

Court held that an admission of a single prior discharge of pollutants justified a sentence enhancement based on an "ongoing, continuous or repetitive discharge".

U.S. v. Corona, No. 96-3-238 (5th Cir.) (108 F.3d 565) (March 12, 1997) (Judge Patrick E. Higginbotham)

United States v. Gaydos, 108 F.3d 505 (3rd Cir. 1997) (Judge Nygaard)
United States v. Corona, 108 F.3d 565 (5th Cir. 1997) (Judge Higginbotham)

Both of these cases deal with the Federal arson statute (18 U.S.C. § 844(i) and the issue of whether every case of arson is a Federal …

U.S. v. Booze, No. 96-3025 (D.C. Cir.) (108 F.3d 378) (March 18, 1997) (Judge Judith W. Rogers)

In Re Sealed Case, 108 F.3d 372 (D.C.Cir. 1997) (Per Curiam)
United States v. Booze, 108 F.3d 378 (D.C.Cir. 1997) (Judge Rogers)

Both of these cases deal with the critically important question of how much drugs may be attributed to a defendant in a drug conspiracy case; and both cases …

U.S. v. McVeigh, No. 96-CR-68-M (D.Colo.) (954 F.Supp. 1441) (January 28, 1997) (Judge Richard P. Matsch)

United States v. Viltrakis, 108 F.3d 1159 (9th Cir. 1997) (Judge Roney)
United States v. McVeigh, 954 F.Supp. 1441 (D.Colo. 1997) (Judge Matsch)

These two cases address another recurrent and fulminic issue: Does an indigent defendant really have the ability to compete fairly with the Government in obtaining funds needed …

U.S. v. Morales, No. 94-10507 (9th Cir.) (108 F.3d 1031) (March 5, 1997) (Judge David R. Thompson)

This en banc decision reverses an old Ninth Circuit decision, U.S. v. Brodie, 858 F.3d 492 (9th Cir. 1988), which held that Rule 704(b) of the Fed.R.Evid. precluded an expert witness from testifying to a predicate matter from which the jury might "extrapolate" whether the defendants possessed the necessary mens …

Singleton v. Norris, No. 95-3032 (8th Cir.) (108 F.3d 872) (March 12, 1997) (Judge Roger L. Wollman)

The petitioner in this case, a black male, was convicted in an Arkansas state court in 1979 of the capital felony murder of a white female. After he was sentenced to death, he began a series of appeals - the latest of which involved his claim that he was not …

Rashad v. Burt, No. 96-1040 (6th Cir.) (108 F.3d 677) (March 14, 1997) (Judge Boyce F. Jr. Martin)

The defendant in this case sought a writ of habeas corpus on the grounds that his State court felony conviction for possession with intent to deliver over 650 grams of cocaine after an earlier conviction for possession of the same substance violated his rights under the Double Jeopardy Clause of …

U.S. v. Contreras, No. 95-2070 (10th Cir.) (108 F.3d 1255) (March 11, 1997) (Judge Wade Brorby)

Case is noted for its discussion of the Congressional history of the money laundering statute and its conclusion that Congress did not intend to create a statute punishing mere "money spending.".

Doe v. Weld, No. Civ. A. No. 96-11968-PBS (D.Mass.) (954 F.Supp. 425) (December 17, 1997) (Judge Patti B. Saris)

Case rejected a broad range of challenges to the Massachusetts Megan's Law, holding it did not constitute punishment for purposes of ex post facto, bill of attainder and double jeopardy clauses; and that it was not cruel and unusual punishment.

U.S. v. Blackwell, No. Crim. No. 95-671 (AJL) (D.N.J.) (954 F.Supp. 944) (January 21, 1997) (Judge Alfred J. Jr. Lechner)

Here Judge Lechner angrily rejected the Government's attempt to seek a downward departure for an inner-city defendant on the basis of extraordinary family responsibilites, claiming it was attempting to set a precdent for a different case.

United States v. Perkins, 108 F.3d 512 (4th Cir. 1997) (Judge Russell)
United States …

U.S. v. Jerez, No. 95-1549 (7th Cir.) (108 F.3d 684) (February 27, 1997) (Judge Kenneth F. Ripple)

This case, involving a late-night search and seizure, covers a full panoply of many of the issues raised in such cases. Two Hispanic defendants, staying in a motel near an airport in Wisconsin, were roused from bed by the police sometime after 11 p.m. one night, principally because they were …

U.S. v. Binford, No. 96-2419 (7th Cir.) (108 F.3d 723) (March 4, 1997) (Judge William J. Bauer)

Adopting the "sentencing package" theory, the Seventh Circuit held that a district court has the authority to restructure a defendant's entire sentence even when the petitioner attacks the validity of just one of the counts of conviction.

Not without reservation, the Seventh Circuit again affirmed what virtually every other circuit …

U.S. v. Bissell, No. Crim. A. No. 95-539 (AJL) (D.N.J.) (954 F.Supp. 841) (December 13, 1996) (Judge Alfred J. Jr. Lechner)

United States v. Perkins, 108 F.3d 512 (4th Cir. 1997) (Judge Russell)
United States v. Griffiths, 954 F.Supp. 738 (D.Vt. 1997) (Judge Sessions)
United States v. Bissell, 954 F.Supp. 841 (D.N.J. 1996) (Judge Lechner)
United States v. Blackwell, 954 F.Supp. 944 (D.N.J. 1997) (Judge Lechner)

As these four cases show, …

U.S. v. Webster, No. 96-30159 (9th Cir.) (108 F.3d 1156) (March 12, 1997) (Judge Eugene A. Wright)

Here, in examining the "purports to be genuine language" contained in USSG § 2B5.1, the Court held that it was not necessary for the Government to prove the common law similitude requirement that most courts have applied to the counterfeiting laws.

In this case, the defendant pled guilty to passing …

U.S. v. Qualls, No. 95-50378 (9th Cir.) (108 F.3d 1019) (March 5, 1997) (Judge Robert R. Beezer)

Case held that the district court committed plain error by failing to instruct jury that it could only convict defendant for possessing those firearms that he was barred from possessing under state statute.

U.S. v. Jerez, No. 95-1549 (7th Cir.) (108 F.3d 684) (February 27, 1997) (Judge Kenneth F. Ripple)

QUOTE OF THE WEEK - The hokum and hypocrisy of the metamorphic "drug dealer profile."

"The 'drug dealer profile' is . . . laughable, because it can be used to justify designating anyone a potential drug courier if the DEA agents so choose. . . . [A] canvass of numerous …

U.S. v. Brown, No. 96-1414 (8th Cir.) (108 F.3d 863) (March 11, 1997) (Judge David R. Hansen)

Court affirmed granting of new trial based on jury's improper consideration of intrinsic evidence and held that trial judge's examination of jurors did not violate mandates of Rule 606(b) of the Fed.R.Evid.

U.S. v. Jones, No. 94-5913 (6th Cir.) (108 F.3d 668) (March 12, 1997) (Judge Alice M. Batchelder)

In Re Sealed Case, No. 96-3036 (D.C. Cir.) (108 F.3d 372) (March 14, 1997) (Per Curiam)

In Re Sealed Case, 108 F.3d 372 (D.C.Cir. 1997) (Per Curiam)
United States v. Booze, 108 F.3d 378 (D.C.Cir. 1997) (Judge Rogers)

Both of these cases deal with the critically important question of how much drugs may be attributed to a defendant in a drug conspiracy case; and both cases …

U.S. v. Gaydos, No. 95-3468 (3rd Cir.) (108 F.3d 505) (March 14, 1997) (Judge Richard L. Nygaard)

United States v. Gaydos, 108 F.3d 505 (3rd Cir. 1997) (Judge Nygaard)
United States v. Corona, 108 F.3d 565 (5th Cir. 1997) (Judge Higginbotham)

Both of these cases deal with the Federal arson statute (18 U.S.C. § 844(i) and the issue of whether every case of arson is a Federal …

U.S. v. Lowe, No. Cr. No. 95-10404-PBS (D.Mass.) (954 F.Supp. 401) (January 16, 1997) (Judge Patti B. Saris)

This detailed and technical decision analyzes the use of DNA testing (using both the RFPL and PCR methods) under Fed.R.Evid. 702, and Judge Saris concluded that it was sufficienlty reliable to be admitted under the standards of Daubert v. Merrill Dow.

U.S. v. Carraway, No. 94-`938 (7th Cir.) (108 F.3d 745) (March 5, 1997) (Per Curiam)

Here, while the court agreed that the admission into evidence fact that five non-testifying co-defendants had pled guilty was more prejudicial than probative, the error was rendered harmless due to the curative instructions given to the jury.

This was one of those massive drug conspiracy cases that charged twenty-seven people …

U.S. v. Morales, No. 94-10507 (9th Cir.) (108 F.3d 1031) (March 5, 1997) (Judge David R. Thompson)

The court explained the "necessary compulsion test" of Rule 704(b) which prohibits an expert's testimony about whether the defendant had the mens rea for the crime but permits testimony about his mental state so long as it does not compel that conclusion.

This en banc decision reverses an old Ninth …

U.S. v. Valdez-Torres, No. 96-3040 (D.C. Cir.) (108 F.3d 385) (March 18, 1997) (Judge Karen LeCraft Henderson)

Here the defendant received a sentence enhancement of four points for use of a dangarous weapon - namely a car. In reejecting his claim of impermissible double counting, the Court concluded that impermissible double counting does not occur "if the enhancement does not duplicate an essential element of the crime." …

U.S. v. Perkins, No. 95-5698 (4th Cir.) (108 F.3d 512) (March 10, 1997) (Judge Donald S. Russell)

Here the Court reversed a downward departure granted to a black defendant on the basis that "symmetry and justice" required a lower sentence - even though the Government failed to object to the departure at sentencing.

United States v. Perkins, 108 F.3d 512 (4th Cir. 1997) (Judge Russell)
United States …

U.S. v. Corona, No. 96-3-238 (5th Cir.) (108 F.3d 565) (March 12, 1997) (Judge Patrick E. Higginbotham)

United States v. Gaydos, 108 F.3d 505 (3rd Cir. 1997) (Judge Nygaard)
United States v. Corona, 108 F.3d 565 (5th Cir. 1997) (Judge Higginbotham)

Both of these cases deal with the Federal arson statute (18 U.S.C. § 844(i) and the issue of whether every case of arson is a Federal …

U.S. v. Griffiths, No. 2:95-CR-55-01 (D.Vt.) (954 F.Supp. 738) (January 11, 1997) (Judge William K. III Sessions)

United States v. Perkins, 108 F.3d 512 (4th Cir. 1997) (Judge Russell)
United States v. Griffiths, 954 F.Supp. 738 (D.Vt. 1997) (Judge Sessions)
United States v. Bissell, 954 F.Supp. 841 (D.N.J. 1996) (Judge Lechner)
United States v. Blackwell, 954 F.Supp. 944 (D.N.J. 1997) (Judge Lechner)

As these four cases show, …