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679 KB
Extraction Summary
7
People
4
Organizations
1
Locations
1
Events
1
Relationships
8
Quotes
Document Information
Type:
Legal document
File Size:
679 KB
Summary
This legal document argues that the extension of the statute of limitations for charges against Maxwell was legally sound. It cites multiple court cases (Enterprise, Weingarten, Cruz v. Maypa) to support the conclusion of Judge Nathan that since the original limitations period had not expired, Maxwell was not deprived of a vested right. The document further asserts that such an extension does not violate the Ex Post Facto Clause of the Constitution.
People (7)
| Name | Role | Context |
|---|---|---|
| Maxwell | Defendant/Subject of the legal argument |
Mentioned as the individual against whom charges were brought and whose statute of limitations was extended.
|
| Judge Nathan | Judge |
Mentioned as the judge who correctly concluded that a 2003 amendment did not deprive Maxwell of vested rights.
|
| Miller | Party in a legal case |
Mentioned in the case citation 'United States v. Miller'.
|
| Weingarten | Party in a legal case |
Mentioned in the case citation 'Weingarten, 865 F.3d at 57'.
|
| Cruz | Party in a legal case |
Mentioned in the case citation 'Cruz v. Maypa'.
|
| Maypa | Party in a legal case |
Mentioned in the case citation 'Cruz v. Maypa'.
|
| Stogner | Party in a legal case |
Mentioned in the case citation 'Stogner, 539 U.S. at 632'.
|
Organizations (4)
| Name | Type | Context |
|---|---|---|
| Court | government agency |
Referred to as 'this Court' which has observed arguments related to the case.
|
| 1st Cir. | government agency |
The United States Court of Appeals for the First Circuit, cited in 'United States v. Miller, 911 F.3d 638, 644-46 (1s...
|
| 4th Cir. | government agency |
The United States Court of Appeals for the Fourth Circuit, cited in 'Cruz v. Maypa, 773 F.3d 138, 145 (4th Cir. 2014)'.
|
| U.S. | government agency |
Refers to the United States Supreme Court in the citation 'Stogner, 539 U.S. at 632'.
|
Timeline (1 events)
2003
A 2003 amendment extended the statute of limitations, which is central to the legal argument concerning Maxwell's case.
Locations (1)
| Location | Context |
|---|---|
|
Mentioned in the case citation 'United States v. Miller'.
|
Relationships (1)
Judge Nathan presided over a matter involving Maxwell and made a ruling that the 2003 amendment did not deprive Maxwell of vested rights.
Key Quotes (8)
"stripp[ed] [defendants] of a complete affirmative defense they previously possessed"Source
— Enterprise case
(Quoted from the Enterprise case to contrast it with Maxwell's situation, where the defense had not yet vested.)
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Quote #1
"did not deprive [Maxwell] of any vested rights."Source
— Judge Nathan
(Judge Nathan's conclusion regarding the 2003 amendment's effect on Maxwell.)
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Quote #2
"colorable arguments"Source
— this Court
(Describing the possibility that the logic of the Enterprise case could extend to criminal cases under certain conditions.)
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Quote #3
"the logic of Enterprise extends to criminal cases where the defendant’s statute of limitations defense had not vested when the limitations period was extended"Source
— this Court
(An observation by the Court regarding the application of the Enterprise case logic.)
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Quote #4
"‘increases the period of time during which a defendant can be sued,’ thereby ‘increasing a defendant’s liability for past conduct.’"Source
— Weingarten case (quoting Enterprise)
(Explaining why extending a limitations period can be seen as increasing a defendant's liability.)
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Quote #5
"the vast weight of retroactivity decisions"Source
— Weingarten case
(Used to describe the body of legal precedent that a claim against extending a non-vested limitations period would contradict.)
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Quote #6
"revoking a vested statute of limitations defense is different from retroactively extending the filing period for a still-viable claim."Source
— Weingarten case
(A key legal distinction recognized by courts, supporting the argument against Maxwell.)
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Quote #7
"in the criminal context, there is a consensus that extending a limitations period before prosecution is time-barred does not run afoul of the Ex Post Facto Clause of the Constitution."Source
— Cruz v. Maypa case
(A statement of legal consensus supporting the constitutionality of extending a statute of limitations before it expires.)
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Quote #8
Full Extracted Text
Complete text extracted from the document (1,728 characters)
Case 22-1426, Document 79, 06/29/2023, 3536060, Page52 of 93
39
the charges against Maxwell did not expire before the
statute of limitations was extended. Thus, unlike En-
terprise, where resurrection of expired claims would
have “stripp[ed] [defendants] of a complete affirmative
defense they previously possessed,” id. at 410, here
Maxwell never possessed that complete defense. Judge
Nathan correctly concluded that the 2003 amendment
accordingly “did not deprive [Maxwell] of any vested
rights.” (A.153).
statute of limitations was extended. Thus, unlike En-
terprise, where resurrection of expired claims would
have “stripp[ed] [defendants] of a complete affirmative
defense they previously possessed,” id. at 410, here
Maxwell never possessed that complete defense. Judge
Nathan correctly concluded that the 2003 amendment
accordingly “did not deprive [Maxwell] of any vested
rights.” (A.153).
To be sure, this Court has observed that there may
be “colorable arguments” that “the logic of Enterprise
extends to criminal cases where the defendant’s stat-
ute of limitations defense had not vested when the lim-
itations period was extended” because the extension
“‘increases the period of time during which a defend-
ant can be sued,’ thereby ‘increasing a defendant’s lia-
bility for past conduct.’” Weingarten, 865 F.3d at 57
(quoting Enterprise, 391 F.3d at 410); see also United
States v. Miller, 911 F.3d 638, 644-46 (1st Cir. 2018)
(discussing potential defense arguments). But such a
claim runs headlong into “the vast weight of retroac-
tivity decisions,” which recognize that “revoking a
vested statute of limitations defense is different from
retroactively extending the filing period for a still-via-
ble claim.” Weingarten, 865 F.3d at 57 (collecting
cases).
be “colorable arguments” that “the logic of Enterprise
extends to criminal cases where the defendant’s stat-
ute of limitations defense had not vested when the lim-
itations period was extended” because the extension
“‘increases the period of time during which a defend-
ant can be sued,’ thereby ‘increasing a defendant’s lia-
bility for past conduct.’” Weingarten, 865 F.3d at 57
(quoting Enterprise, 391 F.3d at 410); see also United
States v. Miller, 911 F.3d 638, 644-46 (1st Cir. 2018)
(discussing potential defense arguments). But such a
claim runs headlong into “the vast weight of retroac-
tivity decisions,” which recognize that “revoking a
vested statute of limitations defense is different from
retroactively extending the filing period for a still-via-
ble claim.” Weingarten, 865 F.3d at 57 (collecting
cases).
For example, “in the criminal context, there is a
consensus that extending a limitations period before
prosecution is time-barred does not run afoul of the Ex
Post Facto Clause of the Constitution.” Cruz v. Maypa,
773 F.3d 138, 145 (4th Cir. 2014); see also Stogner, 539
U.S. at 632 (holding that the Ex Post Facto Clause
consensus that extending a limitations period before
prosecution is time-barred does not run afoul of the Ex
Post Facto Clause of the Constitution.” Cruz v. Maypa,
773 F.3d 138, 145 (4th Cir. 2014); see also Stogner, 539
U.S. at 632 (holding that the Ex Post Facto Clause
DOJ-OGR-00021699
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