United States v. Amaya
853 F. Supp. 2d 835
N.D. Iowa2012Background
- Court held a sanctions hearing on April 30, 2012 regarding the prosecution’s discovery conduct and a Motion To Reconsider.
- Judge previously found bad faith by Special Agent Jensen for failing to disclose GPS monitoring; later withdrew that finding after hearing.
- The court determined the Monte carlo: DEA supervisors directed not to mention GPS devices in reports; policy confusion affected Jensen’s interpretation.
- No sanctions were imposed on the prosecution; mistrial and new trial remedy addressed Brady and Jencks concerns.
- Prosecution’s Motion To Reconsider argued evidence showed Jensen’s intent; court granted the motion and clarified no bad faith, no sanctions.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Was Jensen’s conduct in bad faith? | Amaya argued bad faith by Jensen for hiding GPS use. | Prosecution argued actions followed DEA directives, not bad faith. | No bad faith; sanctions not imposed. |
| Should sanctions be imposed for GPS discovery delay? | Amaya suffered prejudice and delay due to nondisclosure. | No lasting prejudice; remedy included mistrial and new trial. | No sanctions imposed. |
| Did Brady or Jencks violations occur and what remedy applies? | GPS evidence was Brady material and Jencks issues affected witness disclosure. | Remedies already in place (mistrial/new trial) sufficiently cure concerns. | Brady/Jencks concerns mitigated; no new remedy required beyond mistrial/new trial. |
| Does granting the Motion To Reconsider require reinstating bad-faith finding? | Finding of bad faith should stand to sanction the government. | Evidence shows Jensen acted under directives; no bad faith. | Motion To Reconsider granted; no bad-faith finding; no sanctions. |
Key Cases Cited
- United States v. Pherigo, 327 F.3d 690 (8th Cir. 2003) (factors for discovery sanction analysis)
- United States v. Porchay, 651 F.3d 930 (8th Cir. 2011) (Brady remedy via new trial)
- United States v. Babiar, 390 F.3d 598 (8th Cir. 2004) (Brady violation remedies)
- United States v. Stroud, 673 F.3d 854 (8th Cir. 2012) (Jencks Act disclosure scope)
- United States v. Jones, 132 S. Ct. 945 (2012) (DEA policy and GPS monitoring context)