United States v. Ford, No. 12-3687 (8th Cir. 2013)
Annotate this CaseDefendant was acquitted of sexual abuse of an incapacitated person but convicted of kidnapping. On appeal, defendant argued that his acquittal on the sexual abuse count required an acquittal on the kidnapping count as a matter of law. The court concluded that the district court did not plainly err in issuing the first supplemental jury instruction where a jury could have validly concluded that defendant was guilty of kidnapping the victim to prevent her from reporting the sexual assault, despite concluding that defendant was not guilty of sexual abuse; the second supplemental instruction was correct, despite not restating all of the elements of the kidnapping, and the district court was careful to include a second paragraph stating that the instructions should be taken as a whole; the district court did not err in denying defendant's motion for judgment of acquittal where there was sufficient evidence to find defendant guilty of kidnapping; and the district court did not err in denying defendant's motion for a new trial where the district court properly considered the victim's testimony as probative of defendant's motive, properly considered the testimony of witnesses who corroborated the victim's testimony, and defendant's argument that the kidnapping conviction could not stand on its own lacked merit. Accordingly, the court affirmed the judgment.
Court Description: Criminal case - Criminal law. Where the jury acquitted defendant of sexual assault and convicted him of kidnapping, the district court's supplemental instruction validly instructed the jury that it could find Ford guilty to kidnapping despite concluding that he was not guilty of sexual abuse; second supplemental instruction adequately elaborated the "unlawfully seized or detained" element of kidnapping under 18 U.S.C.Sec. 1201(a); evidence was sufficient to support defendant's conviction for kidnapping the victim to prevent her from reporting a sexual assault; the verdicts were not inconsistent as the jury could reasonably belief that the victim wanted to report an assault and defendant prevented her from doing so even if the jury was not persuaded that the government proved all of the elements of the assault beyond a reasonable doubt.
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