United States v. Joseph Maurizio, Jr.
701 F. App'x 129
| 3rd Cir. | 2017Background
- Joseph Maurizio, a U.S. Catholic priest, co-founded ProNiño Honduras and solicited U.S. donations through Honduras Interfaith Ministries (HIM); he traveled regularly to Honduras and sent checks to ProNiño.
- After donors pulled support in 2009, allegations arose that Maurizio sexually abused orphaned boys, used HIM funds for personal purposes, and paid victims; DHS investigated and located victims/witnesses who testified about abuse.
- Search of Maurizio’s rectory computer recovered nude images of minors (metadata tied images to his camera) and folders containing images of named victims; bank records and emails showed HIM funds delivered to Maurizio in Honduras.
- A grand jury indicted Maurizio on eight counts: four counts of illicit sexual conduct with a minor (18 U.S.C. § 2423(c)), one count possession of child pornography (18 U.S.C. § 2252(a)(4)(B)), and three counts of transporting checks abroad to promote illicit sexual conduct (18 U.S.C. § 1956(a)(2)(A)).
- The jury convicted on Counts 1, 2, 3, 4, and 8; the district court granted acquittal on Count 4 post-verdict, denied other post-trial motions (Rule 29 and Rule 33), and sentenced Maurizio to 200 months plus lifetime supervised release.
Issues
| Issue | Plaintiff's Argument (Government) | Defendant's Argument (Maurizio) | Held |
|---|---|---|---|
| Sufficiency/weight of evidence for Counts 1 & 3 (illicit sexual conduct) | Victim and witness testimony, corroborated by other evidence and expert explanation for temporal inconsistencies, supports convictions | Temporal discrepancies in victims’ accounts undermine reliability and require new trial | Convictions for Counts 1 & 3 upheld; district court did not abuse discretion |
| Brady nondisclosure regarding Erick’s Victim Impact Statement (Count 3) | VIS was not material; any apparent recantation stemmed from misunderstanding and could be rebutted by agent testimony | Government suppressed favorable impeachment evidence (VIS) that amounted to recantation and was material | Government’s nondisclosure found but evidence not material; no new trial warranted |
| Sufficiency/weight for Count 2 (possession of child pornography) & affirmative defense under §2252(c) | Images were found on rectory computer and metadata tied them to Maurizio; placement in Recycle Bin did not establish reasonable steps to destroy | Files in Recycle Bin show good-faith attempt to destroy and provide affirmative defense | Conviction on Count 2 upheld; jury could find Recycle Bin not equivalent to destruction |
| Sufficiency for Count 8 (sending checks to promote illicit sexual conduct) | Check memorializing $3,000 for trip, emails requesting cash disbursement, trip expenses matching amount, and testimony that Maurizio paid victims show intent to promote illicit conduct | At time of sending check, no intent to engage in illicit sexual conduct in Honduras; insufficient evidence of intent | Denial of Rule 29 affirmed; evidence sufficient for a rational juror to infer intent |
| Admission of prior bad acts / other-acts evidence under Rule 404(b) and intrinsic-evidence doctrine | Other-acts and financial-transfer evidence admissible to show motive, intent, knowledge, absence of mistake, and to provide background; some testimony intrinsic | Admission was unfairly prejudicial and violated Rule 404(b) / Rule 403 | District court did not abuse discretion; testimony found intrinsic or admissible under Rule 404(b) and Huddleston framework |
Key Cases Cited
- Brady v. Maryland, 373 U.S. 83 (1963) (prosecution must disclose materially exculpatory or impeachment evidence)
- Kyles v. Whitley, 514 U.S. 419 (1995) (materiality defined as reasonable probability that undisclosed evidence would undermine confidence in outcome)
- Giglio v. United States, 405 U.S. 150 (1972) (impeachment evidence affecting witness reliability falls within Brady/Giglio disclosure rule)
- Huddleston v. United States, 485 U.S. 681 (1988) (four-part test for admissibility of other-acts evidence under Rule 404(b))
- United States v. Green, 617 F.3d 233 (3d Cir. 2010) (intrinsic-evidence categories and Rule 404(b) analysis)
- United States v. Starnes, 583 F.3d 196 (3d Cir. 2009) (standard for sufficiency review; deferential to jury verdict)