United States v. Johnson, No. 16-50018 (9th Cir. 2017)Annotate this Case
The Ninth Circuit reversed the district court's denial of defendant's motion for judgment of acquittal where defendant was convicted of obstruction of justice. The basis for defendant's prosecution was his failure to include material information about the use of force upon an inmate in several reports documenting the encounter with the inmate. The panel reviewed the case de novo and applied the federal nexus standard established in Fowler v. United States, 563 U.S. 668 (2011), and held that there was insufficient evidence for any rational juror to find that it was reasonably likely that defendant's reports would have reached federal officers.