United States v. LaFond, No. 14-12574 (11th Cir. 2015)
Annotate this CaseThe issues presented to the Eleventh Circuit in these consolidated appeals of Donald LaFond, Jr. and Jason Widdison, both convicted for second degree murder, was whether the district court abused its discretion in four rulings: (1) the admission of evidence of the defendants’ memberships in gangs; (2) an order that the jurors be identified anonymously; (3) a refusal to give two requested jury instructions about self-defense; and (4) an order that Widdison’s hands remain shackled during his sentencing hearing. Widdison and LaFond, both of whom were inmates in a federal prison, attacked Kenneth Mills, another inmate, who died a month later from his injuries. The government presented evidence that Widdison and LaFond were members of white supremacist gangs who attacked Mills, a white inmate, because he refused to take any action to have his black cellmate replaced. Widdison and LaFond responded that they acted in self-defense after Mills drew a knife to attack LaFond. A jury convicted Widdison and LaFond of second degree murder. Both Widdison and LaFond raised the issue about the admission of evidence of their gang memberships, and Widdison raised the other three issues. The Eleventh Circuit concluded, after review, that the district court did not abuse its discretion when it admitted evidence of the defendants’ memberships in gangs to prove motive or intent, when it ordered that the jurors be identified anonymously to protect their safety, and when it refused to give jury instructions about self-defense that were unsupported by the evidence. The Court also held that the constitutional rule against shackling does not apply to a sentencing hearing before a judge.
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