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United States v. Styles

United States District Court, D. New Jersey

February 14, 2018

UNITED STATES OF AMERICA
v.
FRANCIS J. STYLES, Defendant.

          OPINION

          KEVIN MCNULTY United States District Judge

         This matter comes before the Court on the post-trial motion (ECF no. 61) of the defendant, Francis J. Styles, for a judgment of acquittal, pursuant to Fed. R. Crim. P. 29(c). Trial of the matter ended in a hung jury and declaration of a mistrial.[1] For the reasons expressed herein, the motion will be denied.

         I. Standard Under Rule 29

         A Rule 29(c) motion for a judgment of acquittal is most commonly made after the entry of a guilty verdict. It may also be made, as here, when a jury has been discharged after having "failed to return a verdict." Fed. R. Crim. P. 29(c)(2); see also Fed. R. Crim. P. 29(b).[2]

         Under Rule 29, a defendant who asserts that there was insufficient evidence to sustain a conviction shoulders "a very heavy burden." United States v. Anderson, 108 F.3d 478, 481 (3d Cir. 1997) (quoting United States v. Coyle, 63 F.3d 1239, 1243 (3d Cir. 1995)). The court cannot substitute its judgment for that of the jury. Hence it must view the evidence, and all reasonable inferences therefrom, in the light most favorable to the prosecution, resolving all credibility issues in the prosecution's favor. United States v. Hart, 273 F.3d 363, 371 (3d Cir. 2001); United States v. Scanzello, 832 F.2d 18, 21 (3d Cir. 1987). Having done so, the court must uphold the conviction if "any rational trier of fact could have found the essential elements of the crime beyond a reasonable doubt." Jackson v. Virginia, 443 U.S. 307, 319 (1979) (emphasis in original). Accord United States v. Caraballo-Rodriguez, 726 F.3d 418, 430-31 (3d Cir. 2013) (en banc) (reaffirming principle and reversing a line of drug conspiracy cases that seemingly undermined it); United States v. Silveus, 542 F.3d 993, 1002 (3d Cir. 2008) (issue for trial or appellate court is "whether any rational trier of fact could have found proof of guilt beyond a reasonable doubt based on the available evidence"); United States v. Smith, 294 F.3d 473, 476 (3d Cir. 2002).

         II. Discussion

         A. Charged offenses; knowledge and intent

         Francis Styles, a Bayonne police officer, was indicted for falsification of a report with intent to obstruct an investigation, in violation of 18 U.S.C. § 1519, and misprision of a felony, in violation of 18 U.S.C. § 4. The Indictment alleges that a fellow Bayonne police officer, Domenico Lillo, violated the civil rights of a handcuffed arrestee by striking him in the face with a flashlight. (Lillo later pled guilty to the assault.) Styles is alleged to have covered up the assault by submitting a false incident report.

         The parties agree that the falsification offense under 18 U.S.C. § 1519 has three essential elements:

First: That defendant Styles knowingly concealed, covered up, falsified, or made false entries on a document or record;
Second: That defendant Styles acted with the intent to impede, obstruct, or influence an investigation or proper administration of a matter or in relation to or in contemplation of any such matter or case; and
Third: That the investigation or matter was within the jurisdiction of a department or agency of the United States.

         Misprision of a felony under 18 U.S.C. § 4 has four essential elements:

First: That a federal felony (here, Lillo's deprivation of the victim's civil ...

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