United States v. Maldonado-Passage, No. 20-6010 (10th Cir. 2021)
Annotate this CaseJoseph Maldonado-Passage a/k/a Joe Exotic, the self-proclaimed "Tiger King," was indicted on 21 counts: most for wildlife crimes, and two for using interstate facilities in the commission of his murder-for-hire plots against Carole Baskin. A jury convicted Maldonado-Passage on all counts, and the court sentenced him to 264 months’ imprisonment. On appeal, Maldonado-Passage challenged his murder-for-hire convictions, arguing that the district court erred by allowing Baskin, a listed government witness, to attend the entire trial proceedings. He also disputed his sentence, arguing that the trial court erred by not grouping his two murder-for-hire convictions in calculating his advisory Guidelines range. On this second point, he contended that the Guidelines required the district court to group the two counts because they involved the same victim and two or more acts or transactions that were connected by a common criminal objective: murdering Baskin. The Tenth Circuit Court of Appeal determined the district court acted within its discretion by allowing Baskin to attend the full trial proceedings despite her being listed as a government witness, but that it erred by not grouping the two murder-for-hire convictions at sentencing. Accordingly, the conviction was affirmed, but the sentence vacated and remanded for resentencing.
Some case metadata and case summaries were written with the help of AI, which can produce inaccuracies. You should read the full case before relying on it for legal research purposes.
This site is protected by reCAPTCHA and the Google Privacy Policy and Terms of Service apply.