United States v. Dion, No. 21-1411 (1st Cir. 2022)
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The First Circuit upheld the judgment of the district court denying Defendant's motion to dismiss the indictment against him and convicting Defendant of interstate violation of a protection order under 18 U.S.C. 2262(a)(1), holding that no-contact and stay-away provisions in a conditional release order may constitute a "protection order" as defined by the Violence Against Women Act of 1994 (VAWA), 108 Stat. 1796, 1902.
Defendant was charged with the felony assault of T.N. A state-court judge issued a conditional release order following a bail hearing that included a no-contact provision with T.N. The assault charge was later dismissed due to T.N.'s death. Three years later, a federal grand jury returned an indictment charging Defendant with two counts of interstate violation of a protection order. Defendant filed a motion to dismiss on the grounds that the conditional release order was not a "protection order" as defined under 18 U.S.C. 2266(5). The district court denied the motion to dismiss. The First Circuit affirmed, holding that the no-contact and stay-away provisions in a conditional release order may, under certain circumstances, satisfy the VAWA's definition of a "protection order" as defined in section 2266(5).
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