United States v. Johnson, No. 16-50018 (9th Cir. 2017)
Annotate this CaseThe Ninth Circuit reversed the district court's denial of defendant's motion for judgment of acquittal where defendant was convicted of obstruction of justice. The basis for defendant's prosecution was his failure to include material information about the use of force upon an inmate in several reports documenting the encounter with the inmate. The panel reviewed the case de novo and applied the federal nexus standard established in Fowler v. United States, 563 U.S. 668 (2011), and held that there was insufficient evidence for any rational juror to find that it was reasonably likely that defendant's reports would have reached federal officers.
Court Description: Criminal Law. The panel reversed the district court’s denial of the defendant’s motion for a judgment of acquittal in a case in which the defendant was convicted of obstruction of justice under 18 U.S.C. § 1512(b)(3) for failing to include material information about the use of force upon an inmate in reports documenting the encounter with the inmate. The panel held that the “reasonable likelihood” standard articulated in Fowler v. United States, 563 U.S. 668 (2011), applies to the federal nexus requirement of § 1512(b)(3). Applying the Fowler standard, the panel held that there was insufficient evidence for any rational juror to find that it was reasonably likely that the defendant’s reports would have reached federal officers.
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