US v. Kenneth Ravenell, No. 22-4369 (4th Cir. 2023)
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After a jury trial, Defendant was convicted of one count of conspiracy to commit money laundering. He appealed, arguing that the district court made four errors warranting reversal. First, the district court erred in failing to instruct the jury on the applicable statute of limitations. Second, the court erred in failing to instruct the jury on the definition of “monetary transaction.” Third, the court erred by instructing the jury on conscious avoidance. And fourth, the conviction must be vacated under Yates v. United States, 354 U.S. 298 (1957), because there is no way to determine whether he was convicted on a legally valid theory.
The Fourth Circuit affirmed the district court’s ruling. The court explained that here Defendant offered no affirmative evidence showing that the conspiracy was terminated or that he affirmatively withdrew from the conspiracy prior to the operative July 2, 2014, limitations date. The court wrote that because some conspiratorial acts in Defendant’s case occurred before July 2, 2014, the limitations date did not mean that the district judge was required to provide a statute of limitations instruction. Declining to give one was, therefore, not an abuse of the substantial discretion the court affords district judges in fashioning jury instructions. Moreover, the court held that the government did, in fact, present evidence of conduct undertaken in furtherance of the money laundering conspiracy past July 2, 2014, even though it was not needed for a non-overt act conspiracy.
This opinion or order relates to an opinion or order originally issued on September 7, 2022.
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