The United States Court of Appeals for the Eleventh Circuit is reviewing consolidated appeals by police officers Nathaniel Veal, Jr., Andy Watson, Pablo Camacho, and Charlie Haynes, Jr., who were convicted under 18 U.S.C. § 1512(b)(3) for providing false information regarding the death of a drug dealer. The appeals raise the issue of whether statements previously suppressed in a civil rights trial can be used in an obstruction of justice trial, as established by Garrity v. New Jersey, which protects public employees from losing their Fifth Amendment rights during internal investigations.
The factual background details an incident on December 16, 1988, when the officers, part of the Miami Police Department's Street Narcotics Unit, received a death threat concerning Camacho. They proceeded to the residence of drug dealer Leonardo Mercado, where they encountered him and subsequently found him severely injured and unconscious. Despite emergency response efforts, Mercado died at the scene. Witnesses testified that the officers returned to the police station shortly after, where they were seen entering a lieutenant's office and closing the door. The appeals court affirmed the convictions, addressing issues related to the district judge's rulings on motions to dismiss, statutory interpretation, jury instructions, and the evidence's sufficiency.
Witnesses did not observe any unusual features on Camacho when he entered the lieutenant's office; however, they noted a rip in his shirt and sleeve upon his exit. Photographs taken by an officer in the office showed a long rip in Camacho's shirt, which was missing a pocket, alongside a butcher knife retrieved from the altercation scene and a bag of crack cocaine allegedly seized from Mercado. Later that evening, Camacho requested to be photographed by crime-scene technician Sylvia Romans, who documented significant tears in his shirt and a bruise near his right eye, but noted he had no cuts or bleeding. Random photographs taken by a freelance photographer showed Camacho initially at Mercado's residence with an undamaged shirt. However, subsequent photos in the SNU office depicted a large rip in his shirt that had been taped together.
Two visiting Detroit police officers witnessed an officer leaving Mercado's residence with a rusty butcher knife, which was later seen in the lieutenant's office. Forensic analysis indicated that the tears in Camacho’s shirt were consistent with being cut and then ripped, suggesting the involvement of a mechanical object. Camacho later sought medical treatment for elevated blood pressure and swelling, while the other officers reported no injuries. Following Mercado's death, homicide investigators learned of Camacho's involvement in the altercation, while Veal, Watson, Haynes, and Sinclair claimed they had no physical contact with Mercado and that their presence at Mercado's house was due to observing drug activity, not a death threat to Camacho. They denied meeting with Camacho in the SNU office. At trial, forensic experts analyzed blood stains to establish the interactions and force applied during the incident involving Mercado.
Veal's pants and shoes were found to have blood stains matching those of Mercado, indicating he struck Mercado multiple times with medium to medium-high force. Blood spatter patterns on Veal’s footwear suggested he stamped Mercado’s head, and shoe impressions on Mercado’s clothing matched Veal’s shoe. Watson's pants and sneakers also exhibited blood stains, indicating he was within two to three feet of Mercado during the assault. Blood locations on Watson’s clothing and spatter on nearby walls suggested he was near Mercado’s head while he was upright, not on the ground. A criminology expert linked Watson’s shoe to multiple wounds on Mercado. Haynes had blood on his left shoe and one spot on his shirt, but no stains on his pants due to prior laundering. Evidence indicated that wounds on Mercado’s forehead and cheek were consistent with Haynes's shoe.
Following the incident on December 19, 1988, FBI Agent David Hedgecock initiated an investigation into Mercado’s death, leading to civil rights charges against Camacho, Veal, Watson, Haynes, Sinclair, and Trujillo. The FBI utilized evidence collected by state authorities, including officers’ statements and photographs. The officers attempted to suppress their statements under Garrity, which the district judge granted, determining the statements were protected. The civil rights trial resulted in acquittals for conspiracy, while the jury could not reach a verdict on other substantive charges. After the trial, Sinclair died, and in July 1993, a federal grand jury indicted Camacho, Veal, Watson, and Haynes for conspiracy to obstruct justice and misleading conduct, as well as for perjury and making false statements regarding Mercado’s death.
Officers Veal, Watson, and Haynes moved to dismiss Count II of their charges, citing insufficient facts to constitute a violation of 18 U.S.C. 1512(b)(3), but the district judge denied their motions. They also sought to suppress statements made under Garrity during a civil rights trial, which were similarly denied by the judge. After a ten-week trial, all four defendants—Camacho, Veal, Watson, and Haynes—were convicted on Count II and acquitted of other charges. The judge denied their motions for judgments notwithstanding the verdict and for a new trial. Sentences included thirty months for Camacho and twenty-one months for Veal, Watson, and Haynes, all subject to two years of supervised release, while they remain on bond pending appeal.
On appeal, the officers challenge the denial of their motions to suppress statements regarding Mercado’s death, arguing that these statements, previously suppressed under Garrity, should not have been admissible in the obstruction trial. The Supreme Court's Garrity ruling protects police officers from self-incrimination under coercion, concluding that statements made under threat of termination are inadmissible unless waived knowingly. The district judge found that the officers believed they had to waive their Fifth Amendment rights due to the circumstances surrounding their interrogations. The prosecution alleged that the officers obstructed the investigation into Mercado’s death. The judge allowed the use of their statements in the obstruction trial, reasoning that Garrity does not protect false statements from prosecution for perjury or obstruction. The officers argue that any statements deemed protected by Garrity should be permanently inadmissible in subsequent prosecutions, including for perjury or obstruction of justice.
The argument centers on claims of coercion in obtaining statements from police officers, who argue they would face termination if they did not provide those statements. The Supreme Court has established that the Fifth Amendment does not protect perjured or false statements. Specifically, false testimony presented before a grand jury cannot be suppressed, as perjury undermines judicial integrity and is punishable under federal law. The court upheld a conviction for perjury under 18 U.S.C. § 1623, affirming that a defendant's right to testify does not extend to the right to commit perjury. Immunized testimony does not prevent subsequent prosecution for false statements or perjury. An accused receiving immunity must either testify truthfully, with the understanding their statements cannot be used against them in related criminal prosecutions, or invoke their Fifth Amendment rights without testifying. A witness granted immunity cannot testify falsely without facing potential perjury charges. The principle that the Fifth Amendment does not shield false statements is rooted in legal precedent. Immunity provisions, whether formal or informal, are subject to the same standards, and while use and derivative-use immunity under 6002 protects a witness's testimony from being used against them, it does not protect false statements from prosecution for perjury or false declarations made under oath or during investigations.
The Supreme Court has not specifically ruled on whether false statements made under Garrity protections can insulate a witness from perjury or obstruction of justice charges. However, multiple circuit courts have established that the Fifth Amendment and Garrity do not protect against such charges if a witness knowingly provides false testimony. In **United States ex rel. Annunziato v. Deegan**, the Second Circuit upheld a perjury conviction, determining that the defendant's compelled testimony did not violate his Fifth Amendment rights since he was prosecuted for perjury, not for the underlying criminal activity. The court emphasized that a public employee must not resort to lying as an alternative to self-incrimination or unemployment. The Seventh Circuit followed this rationale in several cases, affirming convictions of police officers for false statements made before a grand jury, despite Garrity protections. In **United States v. Devitt**, the Seventh Circuit ruled that Garrity does not prevent the use of allegedly perjurious statements in criminal prosecutions under 18 U.S.C. 1621 or 1623. The Third Circuit also supported this view in **Fraternal Order of Police, Lodge No. 5 v. City of Philadelphia**, affirming that the Fifth Amendment does not shield individuals from the consequences of perjury. These rulings collectively indicate that Garrity protections do not extend to false statements made during testimony, allowing for prosecution for perjury, false statements, or obstruction of justice. The principle established is that individuals cannot misuse Garrity protections to evade accountability for knowingly providing false information.
Counsel advised Veal, Watson, and Haynes to provide truthful statements to investigators. Under Garrity, while individuals cannot be compelled to incriminate themselves under the threat of job loss, they can still be prosecuted for making false statements during Garrity-protected testimony. False statements constitute an independent crime and are distinct from the related investigation. Courts have established that truthful statements are required to avoid prosecution for perjury or obstruction of justice, as Garrity protections do not allow for dishonesty. Watson and Haynes claimed their statements were coerced in violation of the Fifth Amendment, referencing Mincey v. Arizona. However, the court clarified that Garrity prevents the use of protected statements in criminal prosecutions concerning the investigated matter but does not shield false statements from being admitted in perjury or obstruction trials. The circumstances of the officers' false statements did not meet the standards for coercion outlined in Mincey, especially given their legal counsel's presence. Their choice to provide false statements was voluntary and deliberate, leading to their prosecution for obstruction of justice. The predicament faced by the officers stemmed from their own actions, as Garrity did not permit them to lie without consequence. Their false statements obstructed the investigation into Mercado's death, which would not have warranted prosecution had they been truthful.
Veal, Watson, Haynes, and Camacho challenge the indictment under 18 U.S.C. 1512(b)(3), asserting that it does not constitute a violation of the statute as they interpret it. They argue that the term "another person" in the statute refers specifically to individuals with relevant information about a federal crime, not to state law enforcement agents. Their interpretation suggests that the statute aims to protect those possessing knowledge of a federal offense rather than the investigators receiving that information.
Count II of the indictment alleges that the defendants engaged in misleading conduct towards Florida law enforcement to obstruct the communication of information about the death of Leonardo Mercado, thereby violating 18 U.S.C. 1512(b)(3) and 2. The statute prohibits tampering with witnesses or informants by using intimidation or misleading conduct to hinder communication with federal authorities.
The district judge dismissed the defendants' arguments, and the court reviews statutory interpretations de novo, emphasizing adherence to the plain language of the statute. The court stated that legislative history is unnecessary unless the statute is inherently ambiguous, asserting that clarity in statutory language should be upheld without introducing ambiguity through external interpretations.
The plain language of the statute is deemed conclusive in expressing legislative intent, except in cases of absurdity or internal inconsistencies. To analyze legislative history, it must first be shown that the term “another person” is ambiguous; however, the district court found no ambiguity, as it clearly refers to any person, regardless of their knowledge of a federal crime. The statute prohibits engaging in misleading conduct with the intent to hinder communication to law enforcement regarding federal offenses. The government alleges that Veal, Watson, Haynes, and Camacho misled state investigators about the circumstances of Mercado’s death to obstruct federal investigations. Their actions fall within the statute’s broad definition, and accepting the plain language does not lead to absurd outcomes. The defendants' argument that this interpretation would criminalize all false statements to police is countered by the statute’s requirement for a federal nexus with federal agencies and judges. The misleading conduct of the defendants included false statements about their involvement in Mercado’s death and a collusive meeting to mislead investigators. Camacho's actions involved presenting a torn shirt to suggest Mercado was aggressive, which the jury believed. A plain reading of the statute does not render it redundant or inconsistent with other laws, and the defendants' reliance on the statute’s title to argue against its application to individuals without prior knowledge is unpersuasive.
The doctrine of ejusdem generis is introduced, asserting that general terms following a specific list should be limited to items similar to those listed. However, the court in Turkette ruled the doctrine inapplicable for interpreting the RICO statute. Veal, Watson, Haynes, and Camacho argue that “another person” in the relevant statute should be interpreted narrowly to mean “witness, victim, or informant.” The court clarifies that ejusdem generis is only a construction aid when ambiguity exists. It emphasizes that the statute's language should not be restricted to Congress's intended remedy, referencing Brogan's ruling against limiting the interpretation of 18 U.S.C. § 1001 to only false statements affecting government functions. The argument by Veal and others for a restrictive interpretation is rejected as unfounded, with the statute's language not supporting their definition. The title "witness" does not imply prior knowledge is required, and police officers automatically qualify as witnesses in their investigations. The court also cites precedents suggesting that the terms within the statute should include state investigators. Legislative history supports a nonrestrictive interpretation, indicating Congress's intent to broaden the obstruction of justice statutes rather than limit them. The Senate Report reflects concerns about inadequacies in existing laws concerning obstruction, advocating for a broader reading of 18 U.S.C. § 1512(b)(3) to effectively prevent justice obstruction.
Protection is necessary against unique criminal behaviors that obstruct justice. The Senate Report clarifies that the doctrine of ejusdem generis should not restrict the application of subsection (b)(3) of 18 U.S.C. 1512, which pertains to tampering with witnesses, victims, or informants. Prior to 1982, 18 U.S.C. 1503 addressed witness tampering but was revised to focus solely on officers and jurors. The amendments introduced sections 1512 and 1513, expanding the scope of obstruction of justice offenses. Subsection (b)(3) was intended to encompass a broad array of actions that undermine justice.
The actions of Veal, Watson, Haynes, and Camacho exemplify such conduct, as they engaged in deceptive practices to mislead investigations surrounding Mercado’s death. They provided false information to state investigators, knowing it would be passed on to federal agents. This included utilizing police officers as conduits to propagate misleading evidence. The report emphasizes that Congress aimed for subsection (b)(3) to penalize deceptive tactics that hinder justice, which applies to the conduct of the involved police officers.
Additionally, Veal, Watson, Haynes, and Camacho contended that their convictions under subsection (b)(3) were unjust because they allegedly provided misleading information solely to state investigators, without intent for it to reach federal authorities or pertain to a federal crime.
The statute mandates that a violator must "hinder, delay, or prevent" communication to a federal law enforcement officer or judge regarding a federal offense. The defendants argue that their actions, while potentially violating state law, lacked a sufficient federal connection to support their convictions under 18 U.S.C. § 1512(b)(3). They contend that their misleading information was not directly communicated to federal agents and that there was no ongoing or imminent federal investigation they intended to obstruct at the time of their actions. They also claim the district judge's jury instructions on § 1512(b)(3) misled the jury, leading to erroneous convictions.
The federal nexus argument relates to the specific intent (mens rea) required for a violation of § 1512(b)(3). The district judge instructed the jury that the government must prove three elements beyond a reasonable doubt: (1) the defendant knowingly engaged in misleading conduct; (2) the defendant intended to hinder, delay, or prevent communication to a federal law enforcement officer or judge; and (3) the information pertained to a federal offense. Importantly, the government does not need to establish that the defendant knew the officer or judge was a federal official. The term "law enforcement officer" encompasses federal employees or those authorized to act on their behalf. While the government must prove the defendant intended to obstruct communication regarding a federal offense, it does not need to show that the defendant was aware of the federal nature of the offense. The actions of Veal, Watson, Haynes, and Camacho on December 16 and 17, 1988, are recognized as intentional "misleading conduct" under § 1512(b)(3).
The inquiry focuses on whether individuals (Veal, Watson, Haynes, and Camacho) were aware that their misleading conduct would be communicated at the time it occurred. The legal definition of "misleading conduct" under 18 U.S.C. § 1512(b)(3) encompasses several actions, including: knowingly making false statements; intentionally omitting or concealing information, creating a misleading impression; and knowingly submitting or inviting reliance on false or misleading documents or objects with the intent to mislead. The analysis must consider the specific intent and federal nexus requirements for violations of § 1512(b)(3), as well as examine related statutes such as 18 U.S.C. §§ 1503 and 1512(a), which address corrupt influence on jurors and the prevention of testimony in official proceedings. Subsection 1512(a) prohibits acts intended to prevent testimony or the production of documents in official proceedings, while § 1503 penalizes attempts to influence jurors or obstruct justice through threats or intimidation.
Evading legal process to appear as a witness or produce evidence in an official proceeding, or being absent from such a proceeding, can result in a fine or imprisonment for up to ten years under 18 U.S.C. § 1512(b)(1). Congress has established various obstruction of justice statutes, notably from 18 U.S.C. §§ 1501-1517, each with specific jurisdictional requirements for federal prosecution. Certain clauses of § 1512 necessitate that obstructive actions occur within the context of an "official proceeding," defined in § 1515 as including federal courts, grand juries, congressional hearings, and federal agencies. However, subsections 1512(a)(1)(C) and 1512(b)(3) broaden federal jurisdiction, requiring only that the defendant intended to obstruct communication concerning a federal crime, rather than being tied to an official proceeding. This reflects Congress's intent to protect the integrity of federal investigations by ensuring truthful information transfers. Unlike other provisions of § 1512, subsections (a)(1)(C) and (b)(3) do not require the imminent existence of a federal case. The reliance on United States v. Shively is deemed inappropriate, as it involved witness intimidation related to a state court case, not a federal official proceeding. The Fifth Circuit reversed those convictions due to the lack of federal jurisdiction under § 1512(b)(1), but acknowledged that the actions might fit within the broader scope of § 1512(b)(3), which lacks the "official proceeding" limitation.
A federal judge provided false and misleading information to FBI agents during a grand jury investigation, which does not support the arguments of defendants Veal, Watson, Haynes, and Camacho. The court analyzed the catchall provision of 18 U.S.C. § 1503, prohibiting corrupt efforts to influence or obstruct the "due administration of justice." The court clarified that the term "due administration of justice" requires a temporal, causal, or logical relationship with judicial proceedings. It emphasized that a defendant must possess knowledge that their actions are likely to impact judicial proceedings to establish the intent to obstruct.
In evaluating the sufficiency of evidence for Aguilar's conviction, the court ruled that Aguilar's false statements to an FBI agent failed to establish the necessary nexus to judicial proceedings, as there was no proof he knew those statements would reach a grand jury. The defendants’ attempt to apply the nexus requirement of § 1503 to the different standard under § 1512(b)(3) is incorrect. The court distinguished that § 1512(b)(3) does not require a connection to any ongoing or anticipated judicial proceedings but instead focuses on the transmission of information regarding potential federal crimes to law enforcement. Other obstruction statutes, including § 1505 and § 1511, also highlight different federal interests without necessitating a pending or imminent proceeding. The court underscored that the federal interest varies based on the nature of the affected activity or the status of the targeted individuals, rather than requiring an active judicial process.
Under 18 U.S.C. § 1512(e)(1), a jury may infer that a criminal investigation, including a grand jury proceeding, could be initiated based on obstructive conduct, without needing evidence of a current or imminent investigation. The federal interest addressed by § 1512(b)(3) is highlighted as central to the analysis, superseding the Aguilar interpretation from § 1503. The district judge's instructions aligned with this statute by not requiring proof of an ongoing federal proceeding.
§ 1512(f)(2) specifies that no proof of state of mind is required concerning whether a law enforcement officer or judge is a federal agent. This statute allows state officers to act as federal advisors in law enforcement efforts, particularly in drug interdiction and homicides. For a violation of § 1512(b)(3), it is sufficient to show that false or misleading information is likely to be communicated to federal authorities, regardless of the initial investigators' agency.
Case law supports the interpretation that potential communication with federal authorities suffices for violations under § 1512. The statute does not necessitate an active investigation or intent to initiate one; it is sufficient if there is an intent to impede an individual's potential cooperation with federal officials. The essential mental state required for violations includes the belief that a person might provide information to federal authorities, and actions taken to prevent such communication fall under the statute's scope.
The statute emphasizes the defendant's intent in obstructing a witness's potential communication of information. Under 18 U.S.C. § 1510, a defendant can be found in violation if they believed a witness might provide information to federal officials and took steps to prevent that communication. The defendants, Veal, Watson, and Haynes, argue that § 1512(b)(3) does not apply to their case because their misleading statements were made to state investigators rather than federal ones. However, it is established that the statute does not require the defendant to know the federal nature of the crime involved, as it criminalizes the provision of misleading information related to potential federal offenses, irrespective of the communicator's awareness of its federal implications.
Previous rulings indicate that threats made to prevent witnesses from communicating relevant information, even if unsuccessful, can lead to a conviction under § 1512(b)(3). The intent to hinder communication is sufficient for accountability when false or misleading information pertains to a potential federal crime and is ultimately conveyed to federal authorities. The statute's purpose is to ensure that federal investigations receive accurate information, regardless of the communicator's intentions regarding its reception by federal officials. In this case, evidence demonstrated that misleading information was indeed received by the FBI during its investigation into a civil rights violation linked to Mercado’s death.
The exclusion of a requirement for the defendant to know that misleading information would be communicated to a federal official undermines the specific intent mens rea claimed by Veal, Watson, Haynes, and Camacho. The district judge’s interpretation of 18 U.S.C. § 1512(b)(3) was appropriate, leading to the proper denial of their pretrial motions to dismiss Count II and their post-trial motions challenging jury instructions. The defendants contended that the evidence was insufficient to support their convictions concerning both their conduct (actus reus) and intent (mens rea). However, the district judge rejected their post-trial requests for acquittal or a new trial based on these same arguments. Their claim that acquittal on Count I for conspiracy impacts the sufficiency of evidence for Count II misinterprets the distinction between evidence insufficiency and inconsistent verdicts. According to the Supreme Court, the sufficiency of evidence is assessed independently of jury determinations on other counts. Therefore, the acquittal on Count I does not affect the determination of whether evidence supports convictions under Count II. Legal precedents affirm that inconsistent verdicts do not invalidate a conviction. The court reviews sufficiency challenges de novo, favoring the prosecution's evidence. To prove a violation of § 1512(b)(3), the government must show that the defendant knowingly and willfully engaged in misleading conduct intending to hinder communication to federal authorities about a possible federal crime. The term "another person" is broad, encompassing state investigators who conveyed information to federal authorities. Additionally, § 1512(f) specifies that no specific state of mind is required for a violation of § 1512(b)(3), meaning the officers did not need to know their misleading statements would reach federal authorities or that their conduct constituted a federal crime. The analysis of sufficiency will center on the intentional actions of Veal, Watson, Haynes, and Camacho.
Veal, Watson, and Haynes denied any involvement in the death of Mercado during their statements made on December 17, 1988, despite knowing that Mercado was deceased and that investigators were probing the circumstances of his injuries. They claimed that the struggle was over when they arrived at Mercado's residence and asserted they had not met to discuss the incident at the police station. However, blood-spatter evidence contradicted their statements, indicating that Veal had struck Mercado multiple times, Watson had kicked him in the head several times, and Haynes had also kicked him. The jurors could reasonably disbelieve their claims and infer that the officers colluded to present themselves as uninvolved by misrepresenting their knowledge and actions to investigators, thereby engaging in "misleading conduct" under 18 U.S.C. § 1512(b)(3).
Camacho contested the interpretation of evidence regarding his torn shirt, which he submitted for photographic documentation. He argued that this evidence was insufficient to demonstrate misleading conduct. However, jurors could reasonably conclude that Camacho intentionally tore his shirt to mislead the investigating officers about the altercation’s nature and to fabricate a false narrative regarding Mercado’s death.
Camacho allegedly instructed Romans to photograph his torn shirt in a manner intended to mislead investigators into believing the damage resulted from an altercation with Mercado. This act is identified as Overt Act S in the indictment, while his false claim on police radio regarding the butcher knife being inside Mercado’s residence is noted as Overt Act N. Evidence indicates that the shirt was intact at the scene, and its damage occurred under suspicious circumstances at the police station, suggesting deliberate tampering by Camacho to fabricate exculpatory evidence. The context of Camacho's actions, including the intent to document injuries typically associated with police "control" situations and the forensic evidence contradicting his narrative, supports the inference that he created misleading evidence.
Furthermore, the jury instructions on materiality were challenged, as Veal argued the district judge incorrectly stated that materiality was a legal issue for the court rather than a factual one for the jury, contrary to the precedent set by United States v. Gaudin. This Supreme Court ruling reallocated the determination of materiality for false statements from judges to juries and applies retroactively to cases like this one. The review of potential errors stemming from this instruction is conducted for plain error, given that no objection was raised during the trial.
The materiality definition, contested by Veal, was addressed during the charge conference and the jury instructions. Under 18 U.S.C. § 1001(a), individuals can be fined or imprisoned for making false statements or documents containing materially false information. Plain error review applies to alleged Gaudin errors when no objections were raised at trial, requiring that the error be both obvious and impact substantial rights. The defendants were acquitted of perjury counts under 18 U.S.C. § 1623, rendering those jury instructions irrelevant to the conviction related to 18 U.S.C. § 1512(b)(3). The district judge clarified that the jury should not concern itself with the materiality of false testimony, as that was for the court to decide. In instructing the jury on “misleading conduct,” the judge defined it in several ways, including knowingly making false statements or omitting critical information that misleads. Veal's claims inaccurately extended the perjury count's materiality instruction to the misleading conduct instruction under § 1512(b)(3). The similarities between violations of § 1001 and § 1512(b)(3) were noted, particularly in obstructing federal proceedings, but distinctions exist in how “material” is applied in these statutes.
Intentional concealment of material facts and misleading conduct were central to the case involving Veal and other officers charged under 18 U.S.C. § 1512(b)(3). Veal incorrectly claimed that the court's definition of misleading conduct was immediately followed by a materiality instruction for the jury; however, the instructions were separate and not confusing. The district judge rightly determined that materiality was not for the jury to decide. Veal's argument citing the Gaudin case was dismissed, as the jury, not the judge, evaluated whether the officers' actions constituted misleading conduct. The officers—Veal, Watson, Haynes, and Camacho—sought to overturn their convictions related to misleading or obstructive conduct in the investigation of Mercado's death, disputing the admission of previously suppressed statements and the application of § 1512(b)(3). Ultimately, the court affirmed their convictions based on the presented evidence and the judge's instructions.
