United States v. Reid
2010 U.S. App. LEXIS 24436
| 6th Cir. | 2010Background
- Defendants Wayne and Donna Reid were convicted after a ten-day trial of conspiracy to launder money, six counts of money laundering or aiding and abetting, and harboring a fugitive; a separate forfeiture verdict of $800,000 was entered.
- Evidence showed a large marijuana operation in Clay County, Kentucky, with Jackson, Stewart, Sherry, and Day involved; Reid funds and property were used to support the operation and launder drug proceeds.
- Jackson, a longtime associate, provided hundreds of thousands in cash to Reid; Reid admitted using cash for construction, equipment, and land development associated with Deer Creek Estates.
- The money laundering scheme ran from January 2000 to November 2005, with substantial cash deposits to Reid accounts and transfers of property to Donna Reid after Jackson’s arrest.
- The district court admitted and excluded certain evidence, and the government argued prosecutorial misconduct and limits on cross-examination; the district court also addressed the credibility of cooperating witnesses and the adulterous relationship between witnesses.
- On appeal, the Sixth Circuit affirmed the convictions and held no reversible error on the asserted grounds.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether prosecutorial vouching occurred | Reid | Reid | No reversible error |
| Whether the Hoskins/Hensley cross-examination was improperly limited | Reid | Reid | No abuse of discretion |
| Whether the district court erred in limiting Mobley’s testimony on Reid's character | Reid | Reid | Harmless error |
| Whether Donna Reid’s proffer of evidence of selective prosecution was admissible | Reid | Reid | Excluded evidence proper; no reversible error |
Key Cases Cited
- United States v. Francis, 170 F.3d 546 (6th Cir.1999) (two-step test for prosecutorial misconduct; factors for reversal)
- United States v. Owens, 426 F.3d 800 (6th Cir.2005) (plea agreement credibility considerations)
- United States v. Townsend, 796 F.2d 158 (6th Cir.1986) (plea agreements; credibility and impeachment concerns)
- United States v. Carroll, 26 F.3d 1380 (6th Cir.1994) (prosecutorial statements about witness honesty; limits on remarks)
- United States v. Green, 305 F.3d 422 (6th Cir.2002) (prosecutor may argue credibility without implying personal belief)
- United States v. Emuegbunam, 268 F.3d 377 (6th Cir.2001) (limits on improper vouching analysis)
- United States v. Henry, 545 F.3d 367 (6th Cir.2008) (rebutting witness credibility with permissible argument)
- Delaware v. Van Arsdall, 475 U.S. 673 (1986) (limits on cross-examination under Confrontation Clause)