United States v. Martin, No. 16-4212 (7th Cir. 2018)
Annotate this CaseThe Chicago gang called the Imperial Insane Vice Lords controlled drug operations near Thomas Street and Keystone Avenue. In l2010, the government began investigating the gang’s activities, which led to the indictment of two dozen people for various offenses, including racketeering conspiracies, firearm offenses, narcotics offenses, and murder. Defendants were among the indicted. Trial testimony described the gang’s hierarchy and specific murder plots. After trial and before sentencing, the government disclosed evidence that it had obtained from a confidential informant. The district court held that the late disclosure did not violate Brady v. Maryland because the suppressed evidence was neither exculpatory nor material. The Seventh Circuit affirmed that ruling and the Defendants’ convictions. The court rejected Martin’s claim that the district court violated the Confrontation Clause when it admitted a statement made by a non‐testifying codefendant and erred when it imposed his sentence, treating attempted murders, described at trial, as relevant conduct, and imposing disparate sentences.
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