United States v. Lawson; United States v. Hutto; United States v. Hutto; United States v. Peeler; United States v. Dyal; United States v. Collins, Jr., No. 10-4831 (4th Cir. 2012)Annotate this Case
Defendants were convicted by a jury of violating and conspiring to violate the animal fighting prohibition of the Animal Welfare Act, 7 U.S.C. 2156(a) (the animal fighting statute), resulting from their participation in "gamefowl derbies," otherwise known as "cockfighting." Defendants raised several challenges on appeal. Upon review of the parties' arguments, the court held that the animal fighting statute was a constitutional exercise of Congress' power under the Commerce Clause; that the provision of different elements of the crime in jurisdictions permitting animal fighting did not violate defendants' equal protection rights; and that the district court did not err in conducting Scott Lawson's trial jointly with the trials of his co-defendants. The court held, however, that the juror's misconduct violated Lawson's right to a fair trial, and therefore vacated the convictions for violating the animal fighting statute. The court also vacated the conspiracy convictions with respect to those defendants for which the conspiracy related solely to the animal fighting activities. Further, the court rejected the challenges made by several defendants to the illegal gambling convictions, and affirmed the convictions relating to those offenses as well as the conspiracy convictions for which illegal gambling was one of the objects of the conspiracy alleged.