United States v. Price
4:24-cr-00565
S.D. Tex.May 5, 2025Background
- Lyndell Leroy Price was indicted on charges of conspiracy to commit arson, arson, and conspiracy to use an interstate facility to commit arson in the Southern District of Texas.
- The charged offenses stem from Price orchestrating the arson of a restaurant owned by his business partner, allegedly motivated by revenge after being excluded from a new business venture.
- Price has a prior felony conviction for arson and was on supervised release for federal income tax fraud at the time of these new alleged offenses.
- The Government presented evidence, including credible testimony from an FBI Special Agent and corroborating phone records, showing Price's participation in and leadership of the arson conspiracy.
- Weapons including firearms and a flamethrower were found in Price’s possession, which he is prohibited from having as a felon.
- The court held a detention hearing under the Bail Reform Act and determined whether any conditions of release could reasonably assure community safety and Price’s appearance at trial.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Presumption of detention for dangerousness | Price’s history and new offense require detention | Price has community, family, business ties and no flight history | Presumption not rebutted; detention ordered |
| Flight Risk | Price is a flight risk due to assets and means | Price has deep community and financial ties, no prior flight | Not a flight risk; ties outweigh Government’s concerns |
| Danger to Community | Arson, threats, prior convictions, weapon possession show danger | Bonds and supervision are enough, cooperation shown in past | Danger proven by clear and convincing evidence |
| Conditions of Release | No set of conditions can ensure safety | Supervised release and monitoring suffice | No conditions or combination could ensure safety |
Key Cases Cited
- United States v. Dominguez, 783 F.2d 702 (7th Cir. 1986) (explains what evidence may rebut presumption of detention)
- United States v. Stone, 608 F.3d 939 (6th Cir. 2010) (addresses Congressional intent regarding detention presumption)
- United States v. Hare, 872 F.2d 796 (5th Cir. 1989) (explains continued weight of presumption even if rebutted)
