United States District Court, D. Massachusetts
For Wilkenson Knaggs, Defendant: David P. Hoose, LEAD ATTORNEY, Sasson, Turnbull & Hoose, Northampton, MA.
For City of Springfield, Interested Party: John T. Liebel, City of Springfield, Springfield, MA.
For USA, Plaintiff: Karen L. Goodwin, LEAD ATTORNEY, Deepika B. Shukla, United States Attorney's Office, Springfield, MA.
MEMORANDUM AND ORDER REGARDING DEFENDANT'S RENEWED MOTION FOR A JUDGMENT OF ACQUITTAL AS TO COUNTS 6 & 7
(Dkt. No. 115)
MARK G. MASTROIANNI, United States District Judge.
On September 12, 2013, Wilkenson Knaggs (" Defendant" ) was indicted for three counts of mail fraud under 18 U.S.C. § 1341, two counts of forged endorsement of a security under 18 U.S.C. § 513, and two counts of engaging in monetary transactions in property derived from specified unlawful activity under 18 U.S.C. § 1957. (Dkt. No. 4, Indictment.) A jury trial took place between December 15, 2014 and December 19, 2014. Following the United States' (" Government" ) presentation of evidence, Defendant moved for a directed verdict of acquittal as to, inter alia, the two 18 U.S.C. § 1957 counts. This motion was denied in court. The jury subsequently convicted Defendant on all seven criminal counts with which he was charged.
On January 2, 2015, Defendant filed a timely " renewed motion for a judgment of
acquittal as to counts 6 & 7." (Dkt. No. 115, Defendant's Renewed Motion for Judgment Of Acquittal and accompanying memorandum (" Def. Mem." ).) The Defendant argues the Government failed to present sufficient evidence to permit the jury to infer that the monetary transactions in question affected interstate commerce, as is required by the statute. See 18 U.S.C. § 1957(a), (f). After receiving an extension (Dkt. No. 122), the Government filed an opposition to this motion on January 23, 2015. (Dkt. No. 124.) Defendant filed a reply brief on February 4, 2015 (Dkt. No. 125, Attachment 1, Def. Reply Brief 2), and the Government filed a supplemental opposing memorandum on February 19, 2015 (Dkt. No. 131).
Defendant's argument relies upon a relatively narrow question pertaining to the final instruction, so a full-scale restatement of the facts is unnecessary. Facts relevant to this motion will be discussed below where they are applicable.
The court finds sufficient evidence was presented to permit the inference that Defendant engaged in monetary transactions that sufficiently affected interstate commerce with respect to Counts 6 and 7. The court denies Defendant's motion.
Within 14 days after a jury verdict of guilty, a defendant may renew a previously-brought motion for judgment of acquittal. See Fed R. Crim. P. 29(c)(1). On a defendant's motion for renewed judgment of acquittal under Rule 29 of the Federal Rules of Criminal Procedure, the court " must enter a judgment of acquittal of any offense for which the evidence is insufficient to sustain a conviction." Fed. R. Crim. P. 29(a). The court is tasked with determining " whether any rational factfinder could have found that the evidence presented at trial, together with all reasonable inferences, viewed in the light most favorable to the government, established each element of the particular offense beyond a reasonable doubt." United States v. Richard,234 F.3d 763, 767 (1st Cir. 2000) (quoting United States v. Gabriele,63 F.3d 61, 67 (1st Cir. 1995)). As a result, " [d]efendants challenging convictions for insufficiency of evidence face an uphill battle." United States ...