United States v. Smith, No. 14-50440 (9th Cir. 2016)
Annotate this CaseDefendants Smith, Long, Thompson, Manzo, Craig, Leavins (collectly, the "Joint Appellants"), and Sexton each appealed their convictions for obstruction of justice and conspiracy to obstruct justice. Long and Craig also appealed their convictions for making false statements, and Craig and Leavins appealed their sentences. Furthermore, the Joint Appellants and Sexton raise numerous challenges to the jury instructions. The Joint Appellants and Sexton were all members of the LASD, and were convicted for their roles in interfering with a federal investigation into civil rights abuses at Los Angeles County jails. The court concluded that the district court’s use of the phrase “grand jury investigation,” rather than “grand jury proceeding,” was neither misleading nor an abuse of discretion in these circumstances; the court rejected the claim that a defendant’s unlawful purpose to obstruct justice must be sole or primary; the evidence was sufficient to suggest various motives for the Joint Appellants’ and Sexton’s conduct, so it was appropriate for the court to give an instruction regarding dual purposes; the court rejected the Joint Appellants' challenge to the adequacy of the good faith instruction; the district court did not abuse its discretion in refusing an additional innocent intent instruction; in light of the clear instruction regarding the Joint Appellants’ authority to investigate, any error in the instruction regarding whether or not federal agents actually violated California law was undoubtedly harmless; and the court rejected Craig and Long's challenge to the instructions for the false statement counts. Accordingly, the court affirmed the judgment.
Court Description: Criminal Law. In an opinion addressing challenges to jury instructions, the panel affirmed the district court in a case in which seven defendants, who were members of the Los Angeles Sheriff’s Department, were convicted for their roles in interfering with a federal investigation into civil rights abuses at Los Angeles County jails. Rejecting an argument by six of the defendants (the Joint Appellants) that the instructions misstated the intent element of obstruction of justice under 18 U.S.C. § 1503(a)), the panel held that the instructions were correct and did not permit the jury to convict the Joint Appellants for obstructing an independent FBI investigation rather than for obstructing the grand jury. The panel rejected arguments that a defendant’s unlawful purpose to obstruct justice must be sole or primary. The panel wrote that use of “merely incidental” or “dominant” should be eschewed, but on this record found no reversible error in the instruction given. The panel rejected a claim by James Sexton, who was tried separately, that the degree of unlawful purpose required by § 1503 is so ambiguous that the statute must be construed in his favor. Rejecting the Joint Appellants’ challenge to the adequacy of the district court’s good faith instruction, the panel held UNITED STATES V. SMITH 5 that the instruction properly conveyed that good faith as to one purpose did not mean good faith as to all of them. The panel held that the district court did not abuse its discretion in refusing to give an additional innocent intent instruction. The panel held that in light of a clear instruction regarding the Joint Appellants’ authority to investigate, any error in an instruction regarding whether or not federal agents violated California law was harmless. Rejecting Scott Craig and Maricela Long’s challenge to instructions regarding false statement counts, the panel wrote that neither the dual-purposes instruction nor the good faith instruction applied to the false statement counts, and that the false-statement instructions in any event left no room for the jury to convict Craig and Long if they acted entirely in good faith. The panel addressed other challenges to the defendants’ convictions and sentences in a memorandum disposition.
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