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United States v. Chapman

Citation: 61 F. App'x 512Docket: No. 01-50502; D.C. No. CR-00-00436-LGB-1

Court: Court of Appeals for the Ninth Circuit; April 24, 2003; Federal Appellate Court

Narrative Opinion Summary

This case involves the appeal of a defendant convicted by a jury of attempted bank robbery and carrying and brandishing a firearm during a crime of violence, under 18 U.S.C. § 2113(a)(d) and 18 U.S.C. § 924(c). The defendant challenged the district court's decision to preclude a duress defense and exclude evidence purportedly negating his specific intent to commit the crimes. The appellate court upheld the conviction, reasoning that the defendant had sufficient opportunity to evade the threats from gang members, thereby justifying the exclusion of duress evidence under precedents such as United States v. Shapiro and United States v. Gordon. Furthermore, the defendant's failure to preserve the issue of evidence exclusion for review led the court to apply a plain error standard, ultimately finding the evidence of intent to commit robbery compelling and any error non-prejudicial to the trial's outcome. Circuit Judge Graber dissented, and the memorandum is deemed unsuitable for publication or citation except under specific Ninth Circuit guidelines.

Legal Issues Addressed

Duress Defense Under Federal Law

Application: The court applied the principle by determining that the defendant had an adequate opportunity to escape the threats posed by gang members, thus justifying the exclusion of duress evidence.

Reasoning: The court affirms the conviction, stating that Chapman had adequate opportunity to escape from the gang members who allegedly threatened him, justifying the exclusion of his duress evidence.

Exclusion of Evidence and Specific Intent

Application: The district court's exclusion of testimony relating to the defendant's specific intent was upheld because the defendant did not preserve the issue for review, leading to a plain error analysis.

Reasoning: Chapman also claims that he should have been permitted to testify regarding evidence that could negate his specific intent. However, the district court upheld objections to this testimony, and Chapman did not assert its admissibility on the grounds he now raises on appeal.

Overwhelming Evidence Standard

Application: The court affirmed the conviction by finding that the evidence of the defendant's intent to rob the bank was overwhelming, thereby rendering any potential errors in excluding testimony non-prejudicial.

Reasoning: The court determined that the evidence of Chapman's intent to rob the bank was overwhelming, and any potential error in excluding his proffered testimony did not impact the trial's outcome.

Plain Error Review in Appeals

Application: The appellate court conducted a plain error analysis due to the defendant's failure to preserve the issue of evidence exclusion for review, ultimately concluding that any error did not affect the trial's outcome.

Reasoning: As a result, the issue was not preserved for review, and the appellate court conducted a plain error analysis.