United States v. Davis, No. 11-2325 (2d Cir. 2013)
Annotate this CaseDefendant appealed his conviction for committing an assault resulting in serious bodily injury. The court agreed with defendant that the government failed to present sufficient evidence to prove that the Metropolitan Detention Center (MDC) was within "the special maritime and territorial jurisdiction of the United States." Even though the evidence at trial was insufficient to establish the jurisdictional element of the offense beyond a reasonable doubt, the court affirmed the judgment because the jurisdictional status of the MDC was a "legislative fact" of which the court could take judicial action. The court rejected defendant's remaining claims in a separate summary order. Accordingly, the court affirmed defendant's conviction.
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