United States v. Chunn
3:20-cr-00128
| S.D. Miss. | May 9, 2022Background
- Five defendants (including Aaron Rentfrow) indicted under RICO for membership in the Aryan Circle (AC) and charged with violent offenses: assault with a dangerous weapon causing serious bodily injury, attempted murder to gain/maintain AC status, and assisting offenders to hinder apprehension.
- Standard discovery orders and a protective order limited distribution/copying of discovery, including Jencks and Giglio materials, because of AC’s violent history and alleged practices of identifying cooperators.
- Government provided password‑protected discovery drives to detainees but the Court required that review of Jencks/Giglio material occur only in the presence of defense counsel.
- Rentfrow moved to allow immediate, unsupervised access to Jencks and Giglio materials in detention; the Government opposed based on witness‑safety and intimidation concerns and agreed to early disclosure to counsel only.
- The Court balanced Sixth Amendment fair‑trial/preparation rights against safety concerns, noted the Government had already provided materials to counsel months in advance, cited past AC‑related witness contact, and denied Rentfrow’s motion.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Rentfrow should be allowed unsupervised access to Jencks and Giglio materials before trial | Gov: safety and witness‑intimidation risks from AC justify supervised access; early production to counsel is sufficient | Rentfrow: unsupervised access is necessary to review voluminous material; many statements are public and no specific misconduct alleged | Denied: Court requires review in counsel’s presence due to security concerns and the Government’s accommodation of early disclosure to counsel |
Key Cases Cited
- Giglio v. United States, 405 U.S. 150 (1972) (prosecution must disclose evidence affecting witness credibility)
- United States v. Campagnuolo, 592 F.2d 852 (5th Cir. 1979) (Jencks Act governs timing of production of witness statements)
- United States v. Rivera, [citation="153 F. App'x 758"] (2d Cir. 2005) (upholding limits on defendant access to materials absent counsel supervision)
- United States v. Yassine, [citation="574 F. App'x 455"] (5th Cir. 2014) (trial courts may order defendants and counsel to protect against unwarranted disclosure)