United States v. Little, No. 19-2729 (8th Cir. 2020)
Annotate this CaseThe Eighth Circuit reversed defendant's conviction for escaping from custody after he arrived two days late at a halfway house following a blizzard. The court held that the evidence was insufficient to show he willfully left the extended limits of confinement, because a reasonable jury could not infer that defendant willfully failed to call authorities or arrive at the halfway house as the furlough application required. In this case, there is no evidence that defendant had access to a phone at any of his stopover points. Accordingly, the court remanded for further proceedings.
Court Description: [Per Curiam - Before Erickson, Grasz and Stras, Circuit Judges] Criminal case - Criminal law. Where the government charged defendant escaped from custody when he was late in reporting to his halfway house after his release from prison, the evidence was not sufficient to support his conviction for escape from custody in violation of 18 U.S.C. Sec. 751(a), as there was no evidence in the record that defendant willfully failed to call or arrive at his halfway house on time. Conviction reversed and the case remanded for further proceedings.
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