United States v. Mark Snarr, 704 F.3d 368

Snarr and Garcia were convicted of murdering Gabriel Rhone at the Beaumont U.S. Penitentiary; both defendants were sentenced to death after a jury recommended capital punishment.
Indictment charged Rhone’s murder under 18 U.S.C. §§ 1111 and 2 with notice that the government would seek the death penalty for both defendants.
On Nov. 28, 2007, Snarr and Garcia escaped handcuffs, obtained shanks, attacked Baloney and McQueen, then opened Rhone’s cell and killed Rhone as officers intervened.
Autopsy showed Rhone suffered fifty stab wounds; death caused by multiple stab wounds to heart, lung, and liver.
Jurors found the defendants eligible for the death penalty and later unanimously imposed death sentences after considering statutory aggravators and non-statutory future-dangerousness factors; Defendants timely appealed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Jury selection for cause	Defendants contend district court abused discretion dismissing five death-penalty-objection jurors.	Defendants argue improper for-cause dismissals tainted impartiality.	No abuse; court properly excused jurors unlikely to faithfully apply law and oath.
Lesser-included-offense instruction	Defendants claim Beck v. Alabama requires second-degree murder instruction.	Defendants contend evidence could support conviction of lesser offense.	Beck not violated; no rational basis shown for second-degree instruction given evidence of premeditation.
Sufficiency of evidence for aggravators	Government asserted substantial premeditation, especially heinous/cruel/depraved, and future dangerousness.	Defense disputes existence/weight of evidence for these aggravators.	Evidence sufficient; rational juror could find aggravators beyond reasonable doubt.
Motion to sever	Joint trial was appropriate; severance unwarranted, given lack of prejudice.	Severance needed due to spillover and potential co-defendant testimony issues.	No abuse of discretion; no reversible prejudice from joint trial.
FDPA constitutionality and evidentiary standard	FDPA allows relaxed sentencing evidence; constitutionality challenged.	FDPA violates admissibility rules by relaxing evidence standards.	FDPA constitutionality upheld; relaxed standard does not impair reliability.

Witherspoon v. Illinois, 391 U.S. 510 (1968) (jury impartiality and death-penalty juror excusal principles)
Wainwright v. Witt, 469 U.S. 412 (1985) (standards for excusing jurors based on death-penalty views)
Beck v. Alabama, 447 U.S. 625 (1980) (limits on precluding lesser-included-offense instructions in capital cases)
Martinez–Salazar v. United States, 528 U.S. 304 (2000) (peremptory challenges and cure of cause challenges; jury impartiality focus on seated jurors)
Wharton v. United States, 320 F.3d 526 (2003) (Wharton—relevance of final seated jury when assessing for-cause error)
Zafiro v. United States, 506 U.S. 534 (1993) (severance and spillover prejudice standards in joint trials)
Duren v. Missouri, 439 U.S. 357 (1979) (fair-cross-section and underrepresentation framework)
Castaneda v. Partida, 430 U.S. 482 (1977) (juror cross-section and representativeness principles)
Beasley v. United States", (example placeholder) () ((not used))
Schad v. Arizona, 501 U.S. 624 (1991) (lesser-included-offense instructions limited to supported evidence)