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United States v. Robert Scully

Citation: Not availableDocket: 16-51429

Court: Court of Appeals for the Fifth Circuit; March 3, 2020; Federal Appellate Court

Original Court Document: View Document

Narrative Opinion Summary

In this complex legal case, the defendant, a business owner, was convicted by a jury on charges including conspiracy to defraud the United States and wire fraud related to his company's financial dealings. He appealed the conviction and sentencing, raising several legal issues. The defendant argued that a search of his home office violated the Fourth Amendment, but the court upheld the search, applying the good-faith exception. He also contended that a delay between the indictment and trial violated his Sixth Amendment right to a speedy trial, which the court dismissed, attributing delays to the defendant's own actions. Regarding due process, the defendant claimed that the filing of a second superseding indictment after foreign depositions prejudiced his defense; however, the court found no bad faith or prejudice. The court affirmed the sufficiency of evidence supporting wire fraud convictions, citing deliberate misleading actions by the defendant. The sentencing was deemed reasonable despite being below the guidelines, and the district court's order for over $1 million in restitution was upheld, notwithstanding the defendant's Sixth Amendment challenge. Ultimately, the appellate court affirmed the district court's judgment in all respects.

Legal Issues Addressed

Due Process - Superseding Indictment

Application: The court rejected Scully's due process claim that the second superseding indictment, filed after depositions in Thailand, prejudiced his defense.

Reasoning: The district court found no bad faith on the Government's part and determined that Scully was not prejudiced, thus denying his motion to strike.

Fourth Amendment - Good Faith Exception

Application: The court applied the good-faith exception to the exclusionary rule, allowing evidence obtained from Scully's home office under a search warrant that listed only his primary residence.

Reasoning: The district court denied Scully's suppression motion, ruling that law enforcement's actions were reasonable under the Fourth Amendment and fell within the good faith exception.

Restitution Order - Sixth Amendment Challenge

Application: The court maintained the restitution order, despite Scully's argument that it violated the Sixth Amendment, adhering to existing precedent.

Reasoning: He acknowledged this argument contradicts existing precedent but raised it to preserve the issue for potential Supreme Court review.

Sentencing - Reasonableness of Below-Guidelines Sentence

Application: Scully's sentence was upheld as reasonable, with no clear error in judgment identified in the district court's balancing of sentencing factors.

Reasoning: A below-Guidelines sentence is generally presumed reasonable, and to challenge this presumption, a defendant must demonstrate that the sentence improperly weighed factors or reflected a clear error in judgment.

Sixth Amendment - Right to a Speedy Trial

Application: The court found no violation of Scully's right to a speedy trial, attributing most delays to Scully's own requests and finding no significant prejudice to his defense.

Reasoning: The court upheld the district court's conclusions without finding clear error.

Sufficiency of Evidence - Wire Fraud

Application: The evidence was deemed sufficient to support Scully's convictions for conspiracy to commit wire fraud and multiple counts of wire fraud.

Reasoning: There is sufficient evidence to support Scully's convictions for conspiracy to commit wire fraud and multiple counts of wire fraud, as a reasonable jury could find he engaged in a scheme to defraud.