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United States v. Angelo Ruggiero
Citations: 796 F.2d 35; 1986 U.S. App. LEXIS 27392Docket: 1620
Court: Court of Appeals for the Second Circuit; July 18, 1986; Federal Appellate Court
Ruggiero appeals the revocation of his bail by Judge Costantino, which was based on his threatening behavior towards a witness and the prosecutor in court, as well as his involvement in organized crime while on bail. During a June 1985 hearing, Ruggiero made a threatening gesture towards a witness, which the district judge noted but did not immediately revoke bail. At a subsequent hearing on June 27, 1986, Ruggiero directed aggressive remarks towards a marshal and pointedly threatened the prosecutor, actions witnessed by the judge. The court found these threats sufficient to justify bail revocation, asserting that Ruggiero's conduct indicated a serious risk of obstructing justice. Additionally, evidence from taped conversations and informant testimony suggested Ruggiero's ongoing criminal activities as a high-ranking member of an organized crime family during his bail period, further supporting the decision for revocation. The court addressed the applicability of the Bail Reform Act of 1966 versus the Bail Reform Act of 1984 but concluded that it was unnecessary to resolve this issue. It determined that under either Act, the threats made in court warranted the revocation of bail. The ruling emphasized that a defendant making threats in the presence of a judge must be taken seriously, and it was concluded that Ruggiero's actions indicated he would likely not comply with any conditions of release.