Thank You For Submiting Feedback!
Fed. R. Crim. P. 14 requires a separate trial if it appears that a defendant or the government is prejudiced by a joinder of offenses or of defendants in an indictment or information or by such joinder for trial together.
Under 18 U. S. C. § 2314, three persons named Stracuzza, who admittedly were the common center of a scheme to transport stolen goods, were indicted in a single indictment with the four petitioners for transporting in interstate commerce goods known to have been stolen and having a value in excess of $ 5,000. Count 1 charged two of the petitioners and the Stracuzzas with transporting stolen goods from New York to Pennsylvania; Count 2 charged another petitioner and the Stracuzzas with transporting stolen goods from New York to West Virginia; Count 3 charged another petitioner and the Stracuzzas with transporting stolen goods from New York to Massachusetts; and Count 4 charged all the defendants with a conspiracy to commit the substantive offenses. On motion of petitioners for acquittal at the close of the Government's case, the court dismissed the conspiracy count for failure of proof; but it found that no prejudice would result from a joint trial and submitted the substantive counts to the jury under careful detailed instructions. Petitioners were convicted and the Court of Appeals affirmed, finding that no prejudice resulted from the joint trial.
Was the district court’s refusal to sever the action against defendants and allowance of the aggregation of the value of shipments of stolen goods in interstate commerce to meet the statutory minimum under 18 U.S.C.S. § 2314 proper?
The United States Supreme Court determined that the decision to sever was properly guided by Fed. R. Crim. P. 14. As the district court determined that defendants were not prejudiced by the refusal to sever, the Court affirmed the joint trial of defendants. In addition, the Court reviewed the history of 18 U.S.C.S. § 2314, determining that the statutory minimum for conviction under 18 U.S.C.S. § 2314 was properly defined in the aggregate.