United States v. Marshall, No. 12-2441 (1st Cir. 2014)
Annotate this CaseAppellant had worked for twenty-six years with the United States Postal Service as a letter carrier when he was charged with obstructing the mails in violation of 18 U.S.C. 1701. The statute provides that a defendant who “knowingly and willfully obstructs or retards the passage of mail” shall be fined or imprisoned. After a bench trial, the magistrate judge found Appellant guilty as charged. The district court affirmed. The First Circuit Court of Appeals affirmed, holding (1) even if the trial court’s definition of the term “willfully” was error, any error was harmless beyond a reasonable doubt; (2) the evidence of willful obstruction was sufficient; and (3) the magistrate judge did not deny Appellant due process by continuing the trial date.
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