United States v. Saint Louis, No. 17-4199 (4th Cir. 2018)Annotate this Case
The Fourth Circuit affirmed Defendant Saint Louis and Tulin's convictions for charges stemming from their involvement in the kidnappings of two Americans in Haiti. The court agreed with the district court's observation that, although it certainly was not a perfect trial, the issues raised by defendants ultimately did not warrant reversal. The court held that the district court did not err in refusing to suppress evidence of a codefendant's out-of-court identification of Tulin; by denying defendants' motion for a mistrial based on the introduction of testimony about a previous sexual assault by someone else; by violating Tulin's rights under the Confrontation Clause; by denying him a fair trial; by determining that the weight of the evidence did not warrant a new trial; and by applying a two-level sentencing enhancement for inflicting serious bodily injury.