United States v. William Stegmeier
2012 U.S. App. LEXIS 25460
| 8th Cir. | 2012Background
- Stegmeier allowed Kelley, a fugitive, to stay in an RV at Stegmeier's SD home after Kelley failed to appear for sentencing.
- Kelley resided in the RV during a Minnesota project; Kelley was paid via checks to 'Cash' and Stegmeier disbursed funds.
- A firearm was found in the RV closet near Kelley’s wallet; Stegmeier acknowledged Kelley could have moved it.
- Stegmeier was charged with harboring a fugitive and providing a firearm to a prohibited person; a jury convicted on both counts.
- Stegmeier challenged sufficiency of the evidence, the use of a special verdict form, and jury instructions; he also raised a Second Amendment challenge.
- The district court’s use of a special verdict form and the two challenged jury instructions are reviewed for abuse of discretion.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Insufficiency of evidence harboring a fugitive | Stegmeier allegedly knew of Kelley’s fugitive status and provided shelter. | No direct physical act or concealment established beyond doubt. | Evidence supports harboring; sufficient to sustain conviction. |
| Insufficiency of evidence providing a firearm to a prohibited person | Stegmeier gave Kelley access to the RV, locating the gun, thus disposing to a prohibited person. | No proof of Kelley’s possession or Stegmeier’s transfer of title. | Circumstantial evidence suffices; possession/control shown; conviction sustained. |
| Second Amendment host-liability challenge | Inviting a felon into a home creates prohibited-host liability. | Facts raise constitutional concerns about host liability. | No host-liability issue given the facts; no Second Amendment violation found. |
| Use of a special verdict form | Special interrogatories help ensure unanimity on knowledge of felon/fugitive status. | Special verdict form was improper and duplicative/intrusive. | Not an abuse of discretion; form approved to clarify unanimity on knowledge elements. |
| Challenged jury instructions | Instructions improperly constrained or misled the jury. | Instructions correctly framed the law; not prejudicial when read as a whole. | Instructions upheld; no reversible error. |
Key Cases Cited
- United States v. Hayes, 518 F.3d 989 (8th Cir. 2008) (defining harboring elements and knowledge)
- United States v. Hash, 688 F.2d 49 (8th Cir. 1982) (per curiam on harboring principles)
- United States v. Zerba, 21 F.3d 252 (8th Cir. 1994) (physical act requirement in harboring)
- United States v. Erdman, 953 F.2d 387 (8th Cir. 1992) (shelter as potential harboring act)
- United States v. Van Nguyen, 602 F.3d 886 (8th Cir. 2010) (credibility and jury determinations reserved to jury)
- United States v. Ryan, 9 F.3d 660 (8th Cir. 1993) (special-verdict form guidance)
- United States v. Kroh, 915 F.2d 326 (8th Cir. 1990) (instructional language not error)
- United States v. Moore, 149 F.3d 773 (8th Cir. 1998) (reiteration of Kroh principle)
- United States v. Drefke, 707 F.2d 978 (8th Cir. 1983) (jury instruction duties to follow law)
- United States v. Burrage, 687 F.3d 1015 (8th Cir. 2012) (standard for sufficiency review)
- United States v. Richardson, 439 F.3d 421 (8th Cir. 2006) (unit of prosecution under 18 U.S.C. § 922)