United States v. Bennett, No. 12-3754 (8th Cir. 2014)
Annotate this CaseDefendants Bennett, Jennifer, and Clayton were found guilty of several counts stemming from two fraudulent schemes. Bennett and Clayton appealed their convictions and sentences, and Jennifer appealed her convictions. Clayton died while this appeal was pending. The court vacated Clayton's convictions and remanded his case with instructions to dismiss the indictment as it pertains to him because the criminal proceedings against Clayton abated ab initio. The court concluded that the district court did not err in denying Bennett's motion to dismiss the mail-fraud and mail-fraud-conspiracy counts on the ground that they are barred by the statute of limitations; the district court did not err in denying Bennett's motion for a judgment of acquittal on the mail-fraud charge because the Government presented sufficient evidence to support the jury's verdict; the facts found by the district court did not alter the statutory maximum or minimum sentence that Bennett faced and, therefore, the court rejected Bennett's Alleyne claim; Clayton's death does not necessitate reversal of Bennett's convictions and sentences; and the district court did not err in denying Jennifer's motion to sever her trial from the other defendants.
Court Description: Criminal case - Criminal law. In fraud schemes in which defendant Clayton paid defendants Bennett and Hogeland for services never provided Clayton's employer or paid kickbacks for business opportunities, the convictions against Clayton must be vacated in light of his death while the appeal was pending; with respect to defendant Bennett's appeal, the district court did not err in denying his motions to dismiss the mail-fraud and mail-fraud-conspiracy counts on statute of limitations grounds; the evidence was sufficient to support Bennett's conviction on the mail fraud charge; Alleyne challenge to Bennett's sentence rejected as the facts found by the district court did not alter the statutory maximum or minimum sentence he faced; Clayton's death does not require reversal of Bennett's convictions; no err in denying Hogeland's motion to sever her trial from Clayton and Bennett's. Judge Beam, concurring in part and dissenting in part.
Some case metadata and case summaries were written with the help of AI, which can produce inaccuracies. You should read the full case before relying on it for legal research purposes.
This site is protected by reCAPTCHA and the Google Privacy Policy and Terms of Service apply.