United States v. McRae, No. 14-30995 (5th Cir. 2015)
Annotate this CaseA civilian died after an encounter with a New Orleans officer in the aftermath of Hurricane Katrina. The officer left the civilian's severely wounded body in a car. Defendant, a police officer, set the car on fire with the corpse inside. Defendant was convicted, among other things, of obstructing a federal investigation in violation of 18 U.S.C. 1519. Both sides agree that this conviction must be vacated. The court agreed, based on the Supreme Court's recent decision in Yates v. United States, that defendant's actions do not violate section 1519 because neither a car nor a corpse are tangible objects under the statute. Because defendant's conduct no longer falls within the ambit of section 1519, the conviction and sentence imposed under section 1519 must be vacated. The court affirmed the district court's denial of defendant's motion for a new trial. The court remanded for resentencing.
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