United States v. Michael Woods
710 F.3d 195
| 4th Cir. | 2013Background
- Woods was convicted on 32 counts of a 34-count superseding indictment for tax fraud, wire fraud, and identity theft relating to his tax-preparation business, M&R.
- He was employed full-time by the VA as a data warehouse manager while operating M&R from his home, charging clients a fee and taking deductions from refunds.
- The government contends Woods added false information and used others’ identity data (including VA patients) to inflate refunds, charging $500 per false dependent.
- Woods represented himself at trial with stand-by counsel and testified; the district court sentenced him to 132 months and restitution of $464,599.
- After trial, the district court vacated one identity theft and one aggravated identity theft conviction, leaving 32 counts affirmed on appeal.
- Woods challenges: (1) restriction of his right to testify, (2) closing argument error, (3) instruction on good character, (4) identity-theft instruction, and (5) cumulative error
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Right to testify restrictions | Woods claims restrictions denied his constitutional right | Government permissibly managed testimony for reliability and order | No reversible error; district court exercised reasonable control |
| Prosecutor's closing statement | Statement that Woods lied under oath prejudiced trial | Statement was proper or harmless given evidence | Plain error occurred but not prejudicial to substantial rights; no reversal |
| Good character instruction | District court should give character evidence instruction | Harrison's equivocal testimony did not support instruction | Abuse of discretion to refuse instruction; but no prejudice established |
| Identity theft instructions | Pattern instruction on knowledge and lack of lawful authority required different framing | Charge accurately stated elements considering defendant's theory | District court did not err; instructions were accurate as a whole |
| Cumulative error | Two errors cumulatively prejudiced Woods | No substantial prejudice; errors did not warrant reversal | No reversal due to cumulative error |
Key Cases Cited
- Rock v. Arkansas, 483 U.S. 44 (U.S. 1987) (right to testify has limits; due process foundational)
- Chambers v. Mississippi, 410 U.S. 284 (U.S. 1973) (defendant must comply with rules of procedure and evidence)
- United States v. Moore, 11 F.3d 475 (4th Cir. 1993) (prosecutor cannot call a witness a liar; plain error concerns)
- United States v. Loayza, 107 F.3d 257 (4th Cir. 1997) (prosecutor's personal belief risks improper weighting of testimony)
- United States v. Harrison, 716 F.2d 1050 (4th Cir. 1983) (prosecutor's questions prompting guilt undermine credibility)
- United States v. Mason, 993 F.2d 406 (4th Cir. 1993) (improper assumption of guilt in questioning character witnesses)
- United States v. Smoot, 690 F.3d 215 (4th Cir. 2012) (jury instruction not flawed if fair and accurate statement of law)
- United States v. Allen, 491 F.3d 178 (4th Cir. 2007) (de novo review of jury instructions)
- United States v. Jefferson, 674 F.3d 332 (4th Cir. 2012) (jury instructions reviewed for overall accuracy)