United States v. Sedaghaty, No. 11-30342 (9th Cir. 2013)
Annotate this CaseThis case stemmed from charges that defendant falsified a 2000 charitable organization tax return in order to conceal his support of an independence movement in Chechnya. The case involved significant amounts of classified materials and multiple in camera, ex parte reviews as well as classified proceedings. The court concluded, inter alia, that the government violated its obligations under Brady v. Maryland by withholding significant impeachment evidence relevant to a central government witness; the district court erred in approving an inadequate substitution for classified material that was relevant and helpful to the defense; and the search that the government conducted of defendant's computer hard drives went beyond the explicit limitations of the warrant and the court remanded to the district court to consider the appropriate scope of items seized and whether the exclusionary rule should apply. Considering the errors both individually as well as cumulatively in light of the evidence as a whole, the court concluded that the errors were prejudicial and reversed and remanded for a new trial. The court filed concurrently a classified opinion with respect to the substitution.
Court Description: Criminal Law. The panel affirmed in part and reversed in part a criminal judgment and remanded for a new trial in a tax fraud case – that involved significant amounts of classified materials and in camera, ex parte reviews as well as classified proceedings – stemming from charges that the defendant falsified a 2000 charitable organization tax return in order to conceal his support of an independence movement in Chechnya. The panel was not persuaded by the defendant’s arguments regarding the classified material, the district court’s evidentiary decisions, the notion that the government was one-sided in its effort to obtain evidence abroad, or his view that the government’s characterization of the evidence rose to the level of a constitutional violation. The panel held that the government violated its obligations pursuant to Brady v. Maryland by withholding significant impeachment evidence relevant to a central government witness. After reviewing the classified record, the panel determined that the district court erred in approving an inadequate substitution for classified material that was relevant and helpful to the defense. The panel held that the substitution did not satisfy the requirement in the Classified Information Procedures Act, 18 U.S.C. app. 3 § 6(c)(1), that the summary “provide the defendant with substantially the same ability to make his defense as would disclosure of the specified classified information.” The panel also concluded that the search that the government conducted of the defendant’s computer hard drives went well beyond the explicit limitations of the warrant, and remanded to the district court to consider the appropriate scope of items seized and whether the exclusionary rule should apply. Considering the errors both individually as well as cumulatively in light of the evidence as a whole, the panel concluded that the errors were prejudicial. The panel filed concurrently, under appropriate seal, a classified opinion with respect to the substitution. That opinion also addresses in more detail the defendant’s claim regarding foreign bank records. Concurring in part and dissenting in part, Judge Tallman wrote that the opinion’s recitation of the facts is inappropriately written from the perspective of the defense theory of the case, that the majority unduly constricts the text of the search warrant and disregards the underlying reason for the very existence of the exclusionary rule, that the opinion disregards the district judge’s express factual findings and his rulings on the potential impact of challenged witness testimony following an evidentiary hearing, and that the opinion discounts the extraordinary efforts by the Department of Justice to abide by its criminal discovery obligations and the district court’s extensive oversight of those efforts in dealing with extremely sensitive national security concerns.
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