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729 KB
Extraction Summary
6
People
3
Organizations
1
Locations
2
Events
2
Relationships
6
Quotes
Document Information
Type:
Legal document
File Size:
729 KB
Summary
This legal document is a section of a government filing arguing against a defendant's (Thomas) request for certain records. The government contends that the records—related to BOP staffing, policies, and other employees—are not 'material' to preparing a legal defense under Rule 16. Instead, the government asserts Thomas seeks these records for the impermissible purpose of encouraging jury nullification by arguing that poor conditions at the BOP 'led' to his alleged criminal conduct.
People (6)
| Name | Role | Context |
|---|---|---|
| Thomas | Defendant |
The subject of the motion, seeking records for his defense.
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| Brady |
Referenced in the context of the legal precedent 'Brady' material (exculpatory evidence).
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| Rigas |
A party in the cited case 'United States v. Rigas'.
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| McGuinness |
A party in the cited case 'United States v. McGuinness'.
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| Stevens |
A party in the cited case 'Stevens'.
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| Armstrong |
A party in the cited case 'United States v. Armstrong'.
|
Organizations (3)
| Name | Type | Context |
|---|---|---|
| Government | government agency |
The prosecuting party in the case against Thomas.
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| BOP | government agency |
Bureau of Prisons, mentioned in relation to policies, staffing, and employees.
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| Supreme Court | government agency |
Mentioned for its holding in the case United States v. Armstrong.
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Locations (1)
| Location | Context |
|---|---|
|
Southern District of New York, the court district for cited cases.
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Relationships (2)
Thomas is the defendant in a criminal case being prosecuted by the Government.
Key Quotes (6)
"The Requested Records Are Not “Material” to Preparing a Defense and Are Sought for the Impermissible Purpose of Jury Nullification"Source
— Government
(Section header outlining the Government's main argument.)
DOJ-OGR-00022077.jpg
Quote #1
"led"Source
— Thomas (as characterized by the Government)
(The Government claims Thomas will argue that BOP conditions 'led' to his criminal conduct.)
DOJ-OGR-00022077.jpg
Quote #2
"is material to preparing the defense."Source
— Fed. R. Crim. P. 16(a)(1)(E)
(The legal standard for discoverable items under Rule 16.)
DOJ-OGR-00022077.jpg
Quote #3
"It is [a defendant’s] burden to make a prima facie showing that documents sought under Rule 16(a)(1)(E)(i) are material to preparing the defense."Source
— United States v. Rigas
(A quote from a court case establishing the defendant's burden of proof for discovery requests.)
DOJ-OGR-00022077.jpg
Quote #4
"if it could be used to counter the Government’s case or bolster a defense."Source
— Stevens case
(The definition of what is 'material to preparing the defense' under Rule 16.)
DOJ-OGR-00022077.jpg
Quote #5
"offer more than the conclusory allegation that the requested evidence is material."Source
— Rigas case
(A requirement for a defendant seeking discovery, stating they must provide more than a simple claim of materiality.)
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Quote #6
Full Extracted Text
Complete text extracted from the document (2,156 characters)
Case 1:19-cr-00830-AT Document 35 Filed 04/24/20 Page 15 of 34
B. The Requested Records Are Not “Material” to Preparing a Defense and Are Sought for the Impermissible Purpose of Jury Nullification
All of the records Thomas seeks in his motion are not “material to preparing a defense” under Rule 16, and are not exculpatory under Brady, because they are irrelevant to countering the Government’s false statements case or advancing a legitimate defense. Instead, Thomas seeks evidence of staffing shortages, working conditions, the implementation of BOP policies, supervisory lapses, and instances in which other BOP employees were not prosecuted so that he can engage in attempted jury nullification by arguing that those conditions “led” to the criminal conduct that he is charged with and are a reason to acquit him. (Mot. 5, 7, 9, 14). Thomas is not entitled to records—and certainly would not be entitled to introduce any such evidence at trial— that would aid in that nullification effort because Rule 16 only entitles a defendant to discovery for purposes of bolstering a defense to the Government’s case in chief, not the merits of the decision to prosecute.
1. Applicable Law
An item or record that the Government does not intend to use in its case-in-chief at trial is discoverable under Rule 16(a)(1)(E) only if it “is material to preparing the defense.” Fed. R. Crim. P. 16(a)(1)(E). “It is [a defendant’s] burden to make a prima facie showing that documents sought under Rule 16(a)(1)(E)(i) are material to preparing the defense.” United States v. Rigas, 258 F. Supp. 2d 299, 307 (S.D.N.Y. 2003) (citing United States v. McGuinness, 764 F. Supp. 888, 894 (S.D.N.Y. 1991)). As noted above, an item is “material to preparing the defense” under Rule 16 “if it could be used to counter the Government’s case or bolster a defense.” Stevens, 985 F.2d at 1180-81. The defendant must “offer more than the conclusory allegation that the requested evidence is material.” Rigas, 258 F. Supp. 2d at 307 (internal citation omitted).
As the Supreme Court held in United States v. Armstrong, while Rule 16 authorizes
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DOJ-OGR-00022077
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