United States v. Snyder, No. 16-3779 (7th Cir. 2017)Annotate this Case
Mars, age 19, drove the getaway car for Snyder and Vogt when they robbed a convenience store. The men became nervous that Mars would disclose their crime. Vogt lured Mars to the Decatur sanitation district and murdered her. Snyder was not present. Snyder pleaded guilty to Hobbs Act robbery, 18 U.S.C. 1951(a); brandishing a firearm during a crime of violence, section 924(c); and being a felon in possession of a firearm, section 922(g), and was convicted of conspiring to murder a federal witness, 18 U.S.C. 1512. The court sentenced Snyder to life plus 10‐ and 20‐year concurrent terms. The Third Circuit vacated the section 1512 conviction, which required the government to prove that if Mars had not been murdered, she was reasonably likely to have communicated with a federal law enforcement officer about the robbery. Section 1512 is not satisfied simply because Snyder’s underlying crimes constituted federal offenses, nor by the fact that local police sought FBI assistance with technical aspects of the case. Without the murder, it is unlikely the robbery would have been prosecuted in federal court; although federal officers may have assisted with state prosecution, there is insufficient evidence to find a reasonable likelihood that any federal officer would have communicated with eyewitnesses.