United States v. WATSON
2:21-mj-00038
E.D. Cal.Mar 4, 2021Background
- Court: U.S. District Court for the Eastern District of California; Case No. 2:21-MJ-00038-DB; Order dated March 4, 2021. Defendant: Julius Watson.
- Detention hearing held on the Government's motion under 18 U.S.C. § 3142(f); court made written findings as required by § 3142(i).
- Court found a rebuttable presumption under 18 U.S.C. § 3142(e) applied and that Watson did not present sufficient evidence to rebut it.
- The court determined, based on statutory factors, that the Government proved by a preponderance of the evidence risk of nonappearance and by clear and convincing evidence risk to community safety.
- Primary reasons for detention: strong weight of evidence; prior criminal history; alleged participation in criminal activity while on supervision; history of violence/weapons; substance abuse; unstable employment and residence; lack of ties to district/United States; prior supervision violations.
- Relief ordered: defendant remanded to custody (Attorney General/Marshal), held separate from sentenced prisoners where practicable; right to consult counsel preserved.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Applicability of § 3142(e) rebuttable presumption | Government: charges and defendant's record satisfy statutory categories triggering the presumption | Watson: (attempted) rebuttal argued but court found insufficient evidence to overcome presumption | Court: Presumption applies and defendant failed to rebut it |
| Whether defendant rebutted the presumption | Government: evidence and record show defendant poses danger and flight risk | Watson: presented evidence but not enough to rebut the presumption | Court: Rebuttal insufficient |
| Risk of nonappearance | Government: factors (instability, lack of ties, prior failures to appear) show risk | Watson: likely argued conditions could assure appearance | Court: By a preponderance, no conditions will assure appearance; detention warranted |
| Risk to community safety | Government: prior violence, weapons, crimes while on supervision, substance abuse indicate danger | Watson: likely argued release conditions would mitigate danger | Court: By clear and convincing evidence, no conditions will reasonably assure community safety; detention ordered |
Key Cases Cited
- No reported judicial opinions are cited in this detention order.