United States v. Emmanuel Chaplain
2017 U.S. App. LEXIS 13119
| 8th Cir. | 2017Background
- Chaplain participated with co-defendant Shane Seizys in a series of robberies in Omaha between June 19 and July 16, 2014; GPS ankle-monitor data, surveillance video, eyewitnesses, physical evidence, and DNA tied Chaplain to multiple scenes.
- Robberies targeted national or multi‑state businesses (Jiffy Lube, Subway, O’Reilly Auto Parts, Kum & Go, GameStop, KFC); several locations were temporarily closed, and out‑of‑state goods/supplies were implicated.
- Evidence recovered from an abandoned getaway vehicle and a white Mustang (bandanas, a sweatshirt matching eyewitness descriptions, Xbox display cases with Chaplain’s prints, cash, fictitious plates) linked Chaplain to the crimes.
- Chaplain was indicted on eight Hobbs Act robbery counts (18 U.S.C. § 1951), four counts of brandishing a firearm during a crime of violence (18 U.S.C. § 924(c)), and one count of being a felon in possession of a firearm (18 U.S.C. §§ 922(g), 924(a)(2)).
- After trial, the jury convicted Chaplain of seven Hobbs Act robberies, three § 924(c) brandishing counts, and one felon‑in‑possession count (acquitting on the Jensen Tire count). He received a total sentence of 852 months and appealed.
Issues
| Issue | Plaintiff's Argument (Chaplain) | Defendant's Argument (Government) | Held |
|---|---|---|---|
| Sufficiency of evidence for Hobbs Act convictions | Government failed to prove robberies affected interstate commerce | Ankle GPS, eyewitness, video, physical and business‑closure evidence show interference with interstate commerce | Affirmed: evidence sufficient to show commerce was affected |
| Sufficiency of evidence for § 924(c) brandishing convictions | (Briefed without developed argument) | Evidence of armed robberies established brandishing during crimes of violence | Affirmed; issue deemed abandoned for lack of developed argument |
| Jury instruction wording (failure to insert "interstate" before "commerce") | Instruction was erroneous for omitting "interstate" | Instruction was legally adequate; appellant failed to brief the issue | Affirmed; claim abandoned for failure to argue the point |
| Consideration of pro se filings on appeal | Chaplain submitted pro se documents raising issues | Appellant was represented by counsel; pro se filings need not be considered | Court did not consider pro se filings (affirmed sentence) |
Key Cases Cited
- Adejumo v. United States, 772 F.3d 513 (8th Cir.) (standard for reviewing sufficiency of the evidence)
- Bell v. United States, 761 F.3d 900 (8th Cir.) (view evidence in light most favorable to verdict)
- Colton v. United States, 742 F.3d 345 (8th Cir.) (reasonable inferences support verdict)
- Morales v. United States, 445 F.3d 1081 (8th Cir.) (reverse only if no reasonable jury could convict)
- Howard v. United States, 413 F.3d 861 (8th Cir.) (clarifying standard for sufficiency review)
- Farmer v. United States, 73 F.3d 836 (8th Cir.) (Hobbs Act covers local robberies that affect commerce)
- Quigley v. United States, 53 F.3d 909 (8th Cir.) (robbery of businesses selling out‑of‑state goods usually affects interstate commerce)
- Mann v. United States, 701 F.3d 274 (8th Cir.) (temporary closure of business supports commerce‑effect element)
- Davis v. United States, 30 F.3d 613 (5th Cir.) (closures of gas stations selling out‑of‑state goods satisfied Hobbs Act)
- House v. United States, 825 F.3d 381 (8th Cir.) (robbery that depletes assets of business engaged in interstate commerce satisfies Hobbs Act)
- Taylor v. United States, 136 S. Ct. 2074 (U.S.) (robbery of drug dealer can satisfy commerce element)
- Aldridge v. United States, 561 F.3d 759 (8th Cir.) (issues abandoned if unsupported by developed argument)
- Lalley v. United States, 257 F.3d 751 (8th Cir.) (review of jury instructions is for abuse of discretion)
- Jones v. United States, 698 F.3d 1048 (8th Cir.) (district court may decline to consider pro se filings when defendant is represented)