United States v. Craig Claxton
61 V.I. 715
| 3rd Cir. | 2014Background
- Craig Claxton was indicted (Dec. 2006) for conspiracy to possess with intent to distribute ≥5 kg cocaine (1999–2005) and tried May 24, 2010; convicted by jury; conviction later briefly vacated by the district court then reinstated on appeal; sentence of 120 months imposed after remand.
- Case involved multiple co-defendants, overlapping trials (Mark/Blyden), and cooperating witnesses (Springette, Turnbull, Isaac) who testified about importation and money-collection roles; Turnbull/ Springette wrote letters to government offices asserting hopes for sentence reductions/Rule 35 relief.
- Significant pretrial and inter-district delays: Claxton arrested April 2008 in Florida; held in Puerto Rico for transfer (84 days); trial started ~3.5 years after indictment with numerous co‑defendant motions and interlocutory appeals.
- Trial events: late production of letters from cooperating witnesses (provided during trial), juror contact/tampering alleged (Juror 125 approached with $1,500 offer; Juror 159 informed), some jurors excused and jury sequestered; drug seizure evidence (Sept. 2003) admitted.
- Post-trial motions: Rule 29 judgment of acquittal granted by district court then reversed by Third Circuit; Claxton sought new trial on impartial-jury, evidentiary and Brady/Giglio grounds; also sought safety‑valve relief at sentencing based on a proffer about unrelated matters.
Issues
| Issue | Plaintiff's Argument (Claxton) | Defendant's Argument (Government) | Held |
|---|---|---|---|
| Speedy Trial Act / Sixth Amendment delay | STA and Sixth Amendment violated by long delay from indictment (Dec 2006) to trial (May 2010); oppressive pretrial incarceration and prejudice from 84‑day Puerto Rico detention | Much of delay was excludable or attributable to co‑defendants (interlocutory appeals, numerous motions); government located and arrested Claxton when able; delay justified by case complexity | STA and Sixth Amendment claims denied: STA exclusions and defendant‑caused delay justified timeline; Barker factors weigh for government (no presumptive or specific prejudice) |
| Right to impartial jury (pretrial publicity, tampering, juror misconduct) | Pretrial publicity from Mark/Blyden trial and an organizational chart with Claxton’s name tainted jury; juror tampering (Juror 125) and undisclosed ties (Juror 161) warrant new trial | District court conducted voir dire, excused known‑tainted jurors, sequestered and excluded Jurors 125/159 from deliberations; alleged employment tie was speculative and not shown to create bias | No Sixth Amendment violation: voir dire and instructions adequate against publicity; district court’s Remmer‑style inquiry and remedies for tampering were reasonable; no entitlement to new trial for juror nondisclosure absent proof of bias |
| Admission of drug seizure evidence (Sept. 2003) | Evidence was unfairly prejudicial and not sufficiently connected to charged conspiracy; should have been excluded under Rule 403 | Evidence was highly probative to show existence of conspiracy and Claxton’s role; connection established via Isaac’s testimony | Admission affirmed: probative value outweighed any unfair prejudice; any inconsistencies affected weight, not admissibility |
| Brady / Giglio / Jencks and safety‑valve sentencing relief | Government withheld letters and impeachment material (Turnbull/Springette/Isaac letters) and thus violated Brady/Giglio; also contends the proffer satisfied §5C1.2 safety‑valve (truthfully provided all info) | Letters were produced during trial (or available from co‑defense counsel); no willful suppression nor materiality warranting dismissal; Claxton’s proffer concerned unrelated dog‑fighting matters, not the charged drug conspiracy | Brady/Giglio claims rejected: late disclosure did not constitute willful suppression and defense used material at trial; Isaac letters were obtainable by defense; safety‑valve relief denied because Claxton did not provide all information regarding the charged offense |
Key Cases Cited
- Barker v. Wingo, 407 U.S. 514 (Sup. Ct.) (four‑factor speedy trial test)
- Doggett v. United States, 505 U.S. 647 (Sup. Ct.) (presumptive prejudice and delay analysis)
- Brady v. Maryland, 373 U.S. 83 (Sup. Ct.) (prosecution duty to disclose favorable, material evidence)
- Giglio v. United States, 405 U.S. 150 (Sup. Ct.) (impeachment evidence and witness deals)
- Remmer v. United States, 347 U.S. 227 (Sup. Ct.) (juror tampering presumption and hearing requirement)
- McDonough Power Equip., Inc. v. Greenwood, 464 U.S. 548 (Sup. Ct.) (juror nondisclosure standard for new trial)
- Skilling v. United States, 561 U.S. 358 (Sup. Ct.) (pretrial publicity does not inevitably lead to unfair trial)
- United States v. Velazquez, 749 F.3d 161 (3d Cir.) (analyzed excessive pre‑arrest delay; distinguishes government diligence)
- United States v. Boria, 592 F.3d 476 (3d Cir.) (imputing knowledge in drug conspiracies)
- United States v. Claxton, 685 F.3d 300 (3d Cir.) (prior appeal addressing sufficiency of evidence)