United States v. Hardaway, No. 19-3448 (8th Cir. 2021)
Annotate this CaseThe Eighth Circuit affirmed the district court's judgment in a case where defendant conditionally pleaded guilty to conspiracy to commit money laundering. The court concluded that the district court did not err in denying defendant's motion to dismiss the indictment for lack of venue or to transfer venue to another judicial district. The court explained that, taking the allegations in the indictment as true, there was venue in the Eastern District of Missouri to try the allegation that defendant conspired to commit money laundering in "the Eastern District of Missouri" and elsewhere. The court also rejected defendant's contention that the district court should have transferred venue to the Central District of California. In this case, the district court correctly observed that the investigation into the drug proceeds was conducted in St. Louis, the relevant documents were in St. Louis, witness expenses for defendant's defense would be paid by the government, and defendant's counsel was in St. Louis.
Court Description: [Colloton, Author, with Wollman and Shepherd, Circuit Judges] Criminal case - Criminal law. The district court did not err in denying defendant's motion to dismiss the indictment for lack of venue or to transfer venue to another judicial district; taking the allegations of the indictment as true, there was venue in the Eastern District of Missouri to try the allegation that defendant conspired to commit money laundering in the Eastern District of Missouri and elsewhere; the court did not err in refusing to transfer venue to the Central District of California based on the factors that the investigation occurred in St. Louis, all of the relevant documents were in St. Louis, witness expenses would have to be paid if the case were tried in California, and defendant's attorney was from St. Louis.
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