United States v. Jeremy Hahn, No. 22-1373 (8th Cir. 2023)
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Defendant was convicted of attempted enticement of a minor, travel with intent to engage in illicit sexual conduct, and transfer of obscene material to a minor. The district court sentenced him to 144 months in prison. He appealed his conviction. Defendant argued that the district court erred in admitting parts of his signed plea agreement that the court had not accepted.
The Eighth Circuit affirmed. The court explained that at trial, Defendant’s prior counsel testified that Defendant knowingly and voluntarily signed the plea agreement, noting that he read, discussed, and explained each paragraph to him, specifically covering the waiver. Defendant believes the district court should not have relied on his prior counsel’s testimony alone because it contradicted Defendant’s testimony. But it is the district court’s role to determine the credibility of testimony, and that determination is “virtually unassailable on appeal.” Accordingly, the court found that the district court did not err in finding Defendant waived his Rule 410 rights and admitting parts of the plea agreement.
Further, because Defendant waived his attorney-client privilege on communications about the plea agreement and because his prior counsel properly testified to refute Defendant’s testimony, the district court did not err in allowing the testimony. Finally, the court held that the district court did not err in finding the evidence sufficient to show Defendant took a substantial step toward the enticement of a minor under 18 U.S.C. Section 2422(b).
Court Description: [Benton, Author, with Smith, Chief Judge, and Stras, Circuit Judge] Criminal case - Criminal law. Defendant waived his rights under Federal Rule of Evidence 410 in his signed plea agreement, and it was not an abuse of the district court's discretion to admit portions of the signed plea agreement, even though the court had not accepted it; no error in permitting defendant's former attorney to testify on the issue of whether the plea agreement was entered into voluntarily as defendant had waived the attorney-client privilege on the issue; no error in limiting Rule 412 evidence as defendant failed to file the necessary motion concerning introduction of such evidence; evidence was sufficient to support the defendant's conviction for enticement of minor as defendant took a substantial step toward enticement in violation of 18 U.S.C. Sec. 2422(b).
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