United States v. LAM
1:24-cr-00417
D.D.C.Jun 2, 2025Background
- Hamza Doost was arrested in California on a federal indictment alleging involvement in a sophisticated cryptocurrency laundering conspiracy.
- Magistrate Judge McCormick had ordered Doost released on conditions, but the Government sought to detain him pending trial, arguing he was a flight risk.
- The Government's initial request for detention was denied, but the release order was stayed by the District Court pending further review.
- The District Court conducted a de novo review, considering updated Pretrial Services Reports and submissions from both parties, including added proposed conditions from Doost.
- Doost is a 20-year-old U.S. citizen, student at San Jose State University, with no criminal history and strong family ties in California.
- The Government pointed to Doost’s alleged access to private jet travel without identification and overseas connections as evidence of potential flight risk.
Issues
| Issue | Government's Argument | Doost's Argument | Held |
|---|---|---|---|
| Whether Doost should be detained pretrial as a flight risk | Doost has access to significant resources, private jets, and has traveled internationally, raising flight risk concerns | Doost voluntarily surrendered to authorities, returned to the U.S. from a non-extradition country, and proposed strict release conditions | Government's request for detention denied without prejudice; strict conditions imposed for release |
| Adequacy of proposed release conditions to mitigate flight risk | Existing conditions insufficient due to wealth and methods available to Doost | Additional conditions (home incarceration, parental supervision, equity bond) sufficiently deter flight | Additional conditions accepted; stay lifted once conditions are met |
| Standard and proper procedure for reviewing magistrate release orders | District court should apply a de novo standard of review for release orders | (Not contested) | De novo review granted |
| Risk of danger to community presented by Doost | Possible risk due to sophistication of alleged crimes | No evidence of direct danger; no criminal history | No clear danger to the community found |
Key Cases Cited
- Nken v. Holder, 556 U.S. 418 (Stay standard for emergency motions and four-factor test)
- United States v. Munchel, 991 F.3d 1273 (Standard of review for detention decisions under the Bail Reform Act)
- United States v. Vasquez-Benitez, 919 F.3d 546 (Flight risk/dangerousness analysis under 3142(g))
- United States v. Simpkins, 826 F.2d 94 (Standard of proof for finding risk of flight under the Bail Reform Act)