Law School Case Brief
United States v. Automated Med. Labs., Inc. - 770 F.2d 399 (4th Cir. 1985)
The United States Supreme Court's decisions may be read as establishing a two-pronged inquiry when pre-indictment delay is alleged to violate due process. First, a court must assess whether defendant has suffered actual prejudice, and the burden of proving such prejudice is clearly on defendant. If the threshold requirement of actual prejudice is met, a court must then consider the government's reasons for delay, balancing the prejudice to defendant with the government's justification for delay. The basic inquiry then becomes whether the government's action in prosecuting after substantial delay violates fundamental conceptions of justice or a community's sense of fair play and decency.
On December 12, 1983, a grand jury indicted Automated Medical Laboratories, Inc. ("AML"), along with one of its wholly-owned subsidiaries, Richmond Plasma Corporation ("RPC"), and three individuals, Hugo Partucci, Noberto Queris, and Pedro Ramos, for engaging in a conspiracy that included falsification of logbooks and records required to be maintained in connection with the commercial enterprise of producing blood plasma. The indictment alleged that the falsification of logbooks and records was engaged in to conceal from the Food and Drug Administration ("FDA") various violations of federal regulations governing the plasmapheresis process and facilities. The remainder of the eight-count indictment alleged specific violations of the false statements statute, 18 U.S.C. § 1001, with regard to particular logbooks or records at the RPC facility. AML was convicted of one count of conspiracy, in violation of § 371, and three counts of making and using false documents in a matter within the jurisdiction of a federal agency, in violation of § 1001. On appeal, defendant argued that prosecutorial misconduct, i.e., pre-indictment delay, denied it a fair trial.
By the alleged misconduct displayed by the prosecution, was AML denied of a fair trial?
The Court held that although AML was prejudiced slightly by pre-indictment delay, AML suffered no due process rights violations because the delay by the prosecution did not result from bad faith acts or omissions. According to the Court, AML’s due process rights were not violated because prosecution provided sufficient detail to satisfy the purpose of the bill of particulars and because there was no misconduct in prosecution's questioning of witnesses. Finally, the Court held that the evidence was sufficient to support the jury's verdict. Therefore, AML’s conviction was affirmed.
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