Law School Case Brief
United States v. Smith - 831 F.3d 1207 (9th Cir. 2016)
In order to violate 18 U.S.C.S. § 1503(a), a defendant must have acted with an intent to influence grand jury proceedings, not to influence an investigation independent of the grand jury's authority. a grand jury investigation constitutes a judicial proceeding for purposes of § 1503. Thus, the district court's use of the phrase grand jury investigation, rather than grand jury proceeding, was neither misleading nor an abuse of discretion in these circumstances.
Appellants were all members of the Los Angeles Sheriff's Department. They were indicted for obstruction of justice and conspiracy to obstruct justice. The Joint Appellants were tried, were convicted on all counts, and were sentenced to prison terms. These appeals followed
Was the jury properly instructed on the obstruction of justice counts against the appellants?
The court held that the jury was properly instructed on the obstruction of justice count under 18 U.S.C.S. § 1503(a) as the instructions regarding the intent required for obstruction of justice were correct and did not permit the jury to convict defendants on the invalid theory that they obstructed an independent FBI investigation. The district court properly gave an instruction regarding dual purposes, the instruction properly conveyed that good faith as to one purpose did not mean good faith as to all of them, and the district court did not abuse its discretion in refusing to give an additional innocent intent instruction.
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