United States v. Halstead
2011 U.S. App. LEXIS 4378
4th Cir.2011Background
- Halstead was convicted of healthcare fraud, conspiracy to launder monetary instruments, and related counts, and sentenced to 151 months.
- After Santos (2008) narrowed the meaning of 'proceeds' for money laundering, Halstead filed a 2255 alleging merger and insufficiency of evidence to support money laundering.
- Halstead argued Santos should apply retroactively on collateral review and require definition of proceeds as net profits to avoid merger with healthcare fraud.
- The district court assumed Santos retroactive but held it did not apply to Halstead’s case; the Fourth Circuit granted a certificate on retroactivity.
- The court held Santos retroactive but not relief-worthy here because laundering transactions were distinct from healthcare-fraud transactions and occurred after completion of the fraud.
- The Fourth Circuit affirmed denial of Halstead’s 2255 motion.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| retroactivity of Santos on collateral review | Halstead | Halstead | Santos retroactive on collateral review |
| proceeds interpretation to avoid merger | Halstead | Government | Santos does not mandate merger avoidance here |
| merger present between healthcare fraud and money laundering | Halstead | Government | No merger problem; distinct financial transactions |
| effect of Santos on case outcome | Halstead | Government | Halstead not entitled to relief under Santos |
Key Cases Cited
- United States v. Santos, 553 U.S. 507 (2008) (proceeds meaning net profits to avoid merger)
- Marks v. United States, 430 U.S. 188 (1977) (when no majority opinion, holding may be by narrowest grounds)
- Schriro v. Summerlin, 542 U.S. 348 (2004) (retroactivity of new substantive rules)
- United States v. Singh, 518 F.3d 236 (4th Cir. 2008) (proceeds defined as gross receipts absent merger concerns)