USA v. Lingala, No. 22-2060 (3d Cir. 2024)
Annotate this CaseIn the case before the United States Court of Appeals for the Third Circuit, the appellant, Narsan Lingala, was charged with four counts related to the attempted murder of his ex-wife. On appeal, Lingala argued that the District Court made jurisdictional, procedural, constitutional, and evidentiary errors. The Court of Appeals disagreed and affirmed the conviction. Lingala had argued that federal agents had improperly manufactured federal jurisdiction to prosecute a primarily local crime, but the Court of Appeals found that Lingala himself had initiated interstate travel and used facilities of interstate commerce, which satisfied the jurisdictional element of the statute. Lingala also argued that the District Court should have severed the murder-for-hire counts from the witness tampering counts, but the Court of Appeals found that these charges were connected in a common scheme or plan. Furthermore, Lingala argued that the prosecution team should have been disqualified because they had access to documents seized from Lingala, but the Court of Appeals found that Lingala could not show that the prosecution team had relied on these documents. Finally, Lingala argued that letters he had written to his co-conspirator were inadmissible, but the Court of Appeals found that these letters were properly authenticated, not unfairly prejudicial, and not in violation of the Confrontation Clause or hearsay rules. As a result, the Court of Appeals affirmed Lingala's conviction.
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