United States v. Cornell, No. 13-4630 (4th Cir. 2015)
Annotate this CaseDefendants in this case were three members of a violent street gang known as the Latin Kings who operated as part of the Greensboro, North Carolina chapter of the gang. After a jury trial, Defendants were convicted of conspiracy to violate the Racketeering Influenced and Corrupt Organizations Act based on their activities in connection with the gang. The Fourth Circuit affirmed, holding (1) the district court did not err in instructing the jury that the Government must prove the enterprise activity affected interstate in any way, “no matter how minimal”; (2) the district court did not err in its jury instruction requiring unanimity as to the types of racketeering acts that members of the conspiracy agreed to commit; (3) the district court did not abuse its discretion issuing two Allen charges; and (4) there was no error in the district court’s evidentiary rulings.
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