United States v. Petters
2011 U.S. App. LEXIS 24409
| 8th Cir. | 2011Background
- Petters was convicted on multiple counts of wire fraud, mail fraud, conspiracy, and money laundering after a lengthy trial and five days of deliberations.
- Key evidence included recordings after Deanna Coleman confessed to aiding a multi-billion Ponzi scheme through PCI.
- Reynolds, a Petters associate, testified and the government concealed Reynolds's WITSEC file from admission at trial; Reynolds's name was limited in pretrial proceedings.
- Petters argued the WITSEC file and cross-examination restrictions prevented a complete defense and meaningful confrontation.
- The district court sealed Reynolds's WITSEC file and restricted its use; defense cross-examination highlighted Reynolds's prior frauds and cooperation with government.
- The district court and appellate court concluded Petters' Sixth Amendment rights were not violated and affirmed the conviction and sentence.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| WITSEC file admission and complete defense | Petters asserts Reynolds's WITSEC file is essential to his defense. | Government argues the file is collateral and could confuse issues if admitted. | District court did not abuse discretion; file excluded to avoid confusion. |
| Confrontation and cross-examination limits | Petters claims Reynolds's past crimes should be explored to impeach credibility. | Limiting cross-examination was permissible to avoid harassment and confusion. | Limitations upheld; no clear abuse of discretion; credibility challenged through other cross-examination. |
| Public trial right | Sealing the WITSEC file and restricting Reynolds's references breached public-trial rights. | Secrecy justified by safety and integrity concerns; not a full closure. | Not a violation; partial closures with substantial government interest permitted. |
| Jury instruction for unwitting participant/advice of counsel | District court failed to give context for defense of unwitting participation and reliance on counsel. | Existing instructions adequately conveyed the defense theory and law. | No abuse; instructions sufficiently stated the defense. |
| Pretrial publicity and venue change | Extensive media coverage warranted venue change and presumption of prejudice. | No presumption; voir dire and venire responses mitigated prejudice. | District court did not abuse discretion; no presumption of prejudice. |
Key Cases Cited
- Crane v. Kentucky, 476 U.S. 683 (1986) (right to present a complete defense; due process limit on admissible evidence)
- Michigan v. Lucas, 500 U.S. 145 (1991) (limits on admitting evidence to accommodate legitimate trial interests)
- Taylor v. Illinois, 484 U.S. 400 (1988) (confrontation rights; irrelevance of some cross-examination)
- Waller v. Georgia, 467 U.S. 39 (1984) (public-trial right; closure standards)
- Press-Enterprise Co. v. Superior Court, 464 U.S. 501 (1984) (public-trial protections and closure standards)
- United States v. Dale, 614 F.3d 942 (8th Cir. 2010) (Confrontation Clause limits on cross-examination; abuse of discretion standard)
- United States v. Van Arsdall, 475 U.S. 673 (1986) (scope of cross-examination for credibility and prejudice)