Unted States v. Knight, No. 11-2037 (3d Cir. 2012)
Annotate this CaseThomas and Frett had a gun fight at Frett’s apartment. Both sustained wounds and were hospitalized. Thomas was discharged on May 16; on May 21, six masked gunmen entered the hospital and shot Frett to death. Investigation revealed that they entered through an employee entrance with an employee “swipe card.” The records system showed that Knight, an admissions clerk, accessed Frett’s records hours before he was killed. Knight’s cell phone records indicated that she had telephone conversations with Thomas’s brother, Milligan, that evening. Knight stated that she had no prior knowledge of the shooting and that she did not remember accessing records to ascertain the room number, but admitted that Milligan was her boyfriend. Confronted with phone and system records, Knight admitted the truth and was charged with making false statements to a federal officer, 18 U.S.C. 1001(a)(2), perjury, 18 U.S.C. 1621(1), and conspiring in Frett’s murder. She was acquitted on the false statement and conspiracy charges, but was convicted on three perjury charges and sentenced to 36 months. The Third Circuit affirmed, rejecting claims that the district court admitted irrelevant and unfairly prejudicial evidence and erroneously sentenced her under a USSG provision that applies only to perjury in respect to a criminal offense.
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