United States v. Baptiste, No. 20-1400 (1st Cir. 2021)Annotate this Case
The First Circuit affirmed the judgment of the district judge ordering a joint retrial of Roger Boncy and Joseph
Baptiste in the interest of justice because neither defendant got a fair first trial, holding that Defendants showed deficient performance of counsel and that Defendants were prejudiced.
After a jury trial, Defendants were convicted of conspiring to violate the Foreign Corrupt Practices Act and the Travel Act, and Baptiste was convicted of violating the Travel Act and conspiring to violate the Money Laundering Act. Baptist moved for a new trial based on ineffective assistance of counsel. Boncy also requested a separate trial on the grounds that Baptiste's lawyer's ineffectiveness influenced the jury's view of both defendants and thus impaired Boncy's due process right to a fair proceeding. The district judge found that the cumulative effect of counsel's deficiencies prejudiced both Baptiste and Boncy. The First Circuit affirmed, holding that the government's arguments on appeal were unavailing.
The court issued a subsequent related opinion or order on August 11, 2021.