United States v. Slatten, No. 15-3078 (D.C. Cir. 2017)Annotate this Case
Defendants Slatten, Slough, Liberty, and Heard were contractors with Blackwater, which in 2007 was providing security services to the United States State Department in Iraq. Defendants were convicted of voluntary manslaughter, attempted manslaughter and using and discharging a firearm in relation to a crime of violence. Slatten was also convicted of first degree murder. Defendants' convictions stemmed from shootings in Baghdad that injured or killed at least 31 Iraqi civilians. The D.C. Circuit held that the court has jurisdiction pursuant to the Military Extraterritorial Jurisdiction Act (MEJA), 18 U.S.C. 3261 et seq., and that venue in the District of Columbia was proper; the district court did not abuse its discretion in denying defendants' motion for a new trial based on post-trial statements of a government witness; the evidence was sufficient as to all except one of Liberty's attempted manslaughter convictions; the evidence was sufficient as to Slatten; Slatten's indictment charging first degree murder did not constitute vindictive prosecution; the district court abused its discretion in denying Slatten's motion to sever his trial from that of his co-defendants; and imposition of the mandatory thirty-year minimum under 18 U.S.C. 924(c), as applied here, violated the Eighth Amendment prohibition against cruel and unusual punishment. Accordingly, the court affirmed in part, vacated in part, and remanded.