United States v. William Aossey, Jr.
854 F.3d 453
| 8th Cir. | 2017Background
- Midamar Corporation (founded by William Aossey, later owned by his sons) sold halal-certified meat; USDA regulates meat labeling under the Federal Meat Inspection Act (FMIA).
- USDA investigation (2010) found Midamar employees knowingly forged/falsified export documents for purported halal beef; FSIS withdrew inspection services temporarily and later signaled possible reinstatement.
- In 2014, a grand jury indicted Midamar, William Aossey, and Jalel Aossey for conspiracy, false statements on export certificates (21 U.S.C. § 611(b)(5)), wire fraud, money laundering, and related offenses.
- Defendants moved to dismiss for lack of jurisdiction, arguing FMIA §§ 674 and 607(e) vested exclusive enforcement/remedial authority in the Secretary of Agriculture (channeling disputes to the court of appeals), precluding district criminal prosecutions.
- District court denied the motion (also noting timeliness); Midamar and Jalel pleaded guilty conditionally to preserve appeal; William was convicted at trial. The government does not contest timeliness on appeal; the court reviews the jurisdictional question de novo.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether FMIA §§ 674 and 607(e) divest district courts of jurisdiction over criminal prosecutions for false/misleading meat labeling | District courts retain original jurisdiction over federal offenses under 18 U.S.C. § 3231; criminal prosecution in district court is proper | §§ 674 and 607(e) create an exception channeling label disputes to the Secretary and appeals to circuit courts, which means exclusive administrative remedy and no district criminal jurisdiction | No. Congress did not clearly and unambiguously remove district court jurisdiction; §674 preserves district jurisdiction and §607(e) supplies an administrative remedy that supplements, not supplants, criminal enforcement. |
| Whether routing of administrative appeals to courts of appeals implies repeal of district criminal power | Channeling of administrative appeals does not indicate exclusive enforcement authority | Channeling shows Congress intended Secretary-exclusive enforcement for labeling disputes | Held for plaintiff: channeling is not a clear repeal; it governs appeals from administrative action, not exclusive criminal enforcement. |
Key Cases Cited
- United States v. Jorgensen, 144 F.3d 550 (8th Cir. 1998) (upholding conviction under FMIA misbranding provision)
- Fed. Election Comm’n v. NRA Political Victory Fund, 513 U.S. 88 (1994) (discussing when a novel jurisdictional question may be treated as an original matter)
- United States v. White Horse, 316 F.3d 769 (8th Cir. 2003) (recognizing 18 U.S.C. § 3231 as the usual starting and ending point for federal criminal jurisdiction)
- United States v. Morgan, 222 U.S. 274 (1911) (presumption against implied repeal of traditional prosecutorial powers and against hampering district attorneys/grand juries)
Disposition: Affirmed — district court properly denied the motion to dismiss; criminal prosecution in district court permitted, FMIA §§ 674 and 607(e) do not strip that jurisdiction.