United States v. Angel Amaya
2014 U.S. App. LEXIS 6573
| 8th Cir. | 2014Background
- Amaya was tried three times for conspiracy to launder money and to possess with intent to distribute multiple drugs after two mistrials.
- The first mistrial occurred when a witness testimony inadvertently suggested the defendant was a drug dealer after a sealed in limine order was not received by the parties.
- In the second trial, a hidden GPS surveillance issue was raised; Amaya moved for mistrial and for dismissal with prejudice, which the court denied.
- The district court later held, in an evidentiary hearing, that the GPS disclosure package was inadvertently omitted and that Agent Jensen acted in good faith under DEA policy, denying sanctions.
- In 2012, after Supreme Court guidance in United States v. Jones, Amaya moved to suppress GPS evidence and argued discovery violation; suppression was denied, sanctions were not imposed, and Amaya was convicted in the third trial, resulting in an 180-month sentence.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether double jeopardy barred retrial after two mistrials | Amaya argues the two mistrials reflect prosecutorial misconduct aimed at provoking mistrial | United States contends no prosecutorial intent to provoke mistrial and no pattern of misconduct | No; conviction after two mistrials does not violate double jeopardy |
| Whether the GPS-surveillance discovery violation warranted sanctions or dismissal | Amaya asserts discovery violation and seeks sanctions or dismissal | Government asserts inadvertent omission and no bad faith; sanctions unnecessary | District court did not abuse discretion in denying sanctions or dismissal |
| Whether the first mistrial was provoked by government conduct due to a docketing issue | Amaya contends the first mistrial occurred due to government actions | Prosecution argues it was a docketing snafu, not intended to provoke mistrial | Not clearly erroneous; first mistrial not provoked by government |
| Whether the district court properly balanced factors for discovery sanctions | Amaya argues harsher sanction or dismissal warranted | Government shows no bad faith and prejudice was remedied | No abuse of discretion; sanctions not warranted |
| Whether the Jones framework supports admissibility/suppression of GPS evidence | GPS data should be suppressed as illegal surveillance | No Fourth Amendment violation and inadvertent disclosure not dispositive | Suppression denied; no Fourth Amendment violation found in district court |
Key Cases Cited
- United States v. Bearden, 265 F.3d 732 (8th Cir. 2001) (double jeopardy review of mistrial-related reprosecution)
- United States v. Radosh, 490 F.3d 682 (8th Cir. 2007) (intent not clearly erroneous regarding mistrial provoking conduct)
- United States v. Beeks, 266 F.3d 880 (8th Cir. 2001) (prosecutor conduct counsels against reprosecution after mistrial)
- United States v. Standefer, 948 F.2d 426 (8th Cir. 1991) (double jeopardy not violated after multiple mistrials absent prosecutorial intent)
- United States v. Jordan, 429 F.3d 1032 (11th Cir. 2005) (prosecutor's opposition to mistrial as factor in provocation analysis)
- Branch v. United States, 591 F.3d 602 (8th Cir. 2009) (jury exposure to improper testimony generally cured by less drastic measures)
- Jones v. United States, 132 S. Ct. 945 (Supreme Court 2012) (Georgia? landmark GPS/4th Amendment framework for surveillance evidence)
- Oregon v. Kennedy, 456 U.S. 671 (1982) (prosecution cannot intentionally provoke mistrial to avoid loss of case)