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United States v. Michel

Citation: Not availableDocket: Criminal No. 2019-0148

Court: District Court, District of Columbia; September 13, 2022; Federal District Court

Original Court Document: View Document

Narrative Opinion Summary

The case involves the prosecution of a defendant facing multiple charges related to conspiring with a co-defendant to launder foreign funds in an attempt to influence U.S. elections and policy. The defendant filed several motions to dismiss the indictment, challenging the constitutionality of the Foreign Agents Registration Act (FARA), claiming selective prosecution, and citing outrageous government conduct. The court denied most motions, except for the claim of outrageous conduct, which is partly held in abeyance pending a hearing. The indictment details conspiracies involving illicit campaign contributions and lobbying efforts with foreign principals, implicating the defendant in orchestrating these activities. The court found no merit in the defendant's arguments regarding FARA's vagueness and rejected the selective prosecution claim due to a lack of evidence of discriminatory intent. The advice-of-counsel defense was also deemed inapplicable for dismissal at this stage. The court agreed to hold an evidentiary hearing to further explore claims of vindictive prosecution in relation to a superseding indictment. Ultimately, the rulings emphasize procedural adherence and the sufficiency of charges as alleged in the indictment.

Legal Issues Addressed

Advice of Counsel Defense

Application: The defendant's reliance on advice of counsel is deemed inadequate to dismiss the indictment, as this defense is factual and should be raised at trial rather than during a motion to dismiss.

Reasoning: The advice-of-counsel defense raised by Defendant cannot serve as a basis to dismiss the indictment, as such defenses are factual and should be addressed at trial, not at the motion to dismiss stage.

Foreign Agents Registration Act (FARA) and Vagueness

Application: The court rejects claims that FARA is unconstitutionally vague, emphasizing that the statute provides clear notice of prohibited conduct and requires registration to ensure transparency.

Reasoning: FARA (Foreign Agents Registration Act) and Section 951 do not penalize speech but the failure to register, thus any First Amendment facial challenge is unsuccessful.

Outrageous Government Conduct

Application: The court holds in abeyance the motion claiming outrageous government conduct pending an evidentiary hearing to explore potential constitutional violations by the government.

Reasoning: The Court denied all motions except for the outrageous conduct claim, which remains partially held in abeyance pending an evidentiary hearing.

Selective Prosecution under the Fifth Amendment

Application: The court finds the defendant's selective prosecution claim insufficient due to a lack of evidence of discriminatory intent or disparate treatment compared to similarly situated individuals.

Reasoning: The Defendant claims selective prosecution under the Due Process Clause of the Fifth Amendment, which requires clear evidence to counter the presumption of regularity in the Government’s charging decisions.

Vindictive Prosecution and Superseding Indictments

Application: The court will examine claims of vindictive prosecution related to the filing of a superseding indictment, requiring the defendant to demonstrate a realistic likelihood of vindictiveness.

Reasoning: The defendant's assertion of vindictive prosecution regarding the superseding indictment requires a showing of realistic likelihood of vindictiveness, at which point the Government must provide objective justification.