United States v. Narsan Lingala, 91 F.4th 685

Narsan Lingala was convicted by a jury on four counts related to attempting to hire someone to murder his ex-wife and witness tampering involving his co-conspirator and a police officer.
Lingala's involvement began after a contentious divorce and an arrest for unpaid alimony/child support, when he solicited a fellow inmate to arrange a hit on his ex-wife.
The murder-for-hire plot was uncovered through cooperation between the inmate (acting as a go-between) and law enforcement, who recorded Lingala’s interactions with an undercover detective posing as a hitman.
After his arrest, Lingala attempted to dissuade his girlfriend/co-conspirator from testifying against him via threatening letters, and attempted to bribe or threaten a law enforcement officer involved in his case.
Lingala challenged his conviction on multiple grounds, claiming errors related to jurisdiction, evidentiary rulings, joinder of counts, and the prosecution’s use of privileged documents recovered during his transfer to federal custody.

Issue	Lingala's Argument	Government's Argument	Held
Federal Jurisdiction	Jurisdiction was “manufactured” by federal officials.	Lingala voluntarily used interstate means and travel.	Court found jurisdiction was proper under the statute.
Joinder of Counts	Witness tampering should be severed from murder counts.	Charges were part of a common scheme and properly joined.	Joinder was appropriate under Rule 8(a), no prejudice.
Disqualification of Prosecution	Prosecution team accessed privileged evidence.	No use of privileged documents at trial, no prejudice shown.	No abuse of discretion in refusing to disqualify.
Admission of Threatening Letters	Letters were inadmissible (authenticity/403/Confront).	Letters properly authenticated and highly probative.	Letters inadmissibility arguments rejected.

United States v. Faison, 679 F.2d 292 (3d Cir. 1982) (Archer concept of manufactured jurisdiction not adopted in Third Circuit)
United States v. Jannotti, 673 F.2d 578 (3d Cir. 1982) (en banc) (Archer's holding is limited and not widely applicable)
United States v. Reicherter, 647 F.2d 397 (3d Cir. 1981) (heavy burden for showing prejudice under Rule 14(a) for misjoinder)
United States v. Browne, 834 F.3d 403 (3d Cir. 2016) (burden of proof for authenticity is slight)
United States v. Gatto, 995 F.2d 449 (3d Cir. 1993) (evidence of threats admissible to show consciousness of guilt)
Melendez-Diaz v. Massachusetts, 557 U.S. 305 (2009) (defendant’s own statements not barred by Confrontation Clause)