United States v. Thompson

219 F. Supp. 3d 502 · 2016

Facts

Randy Thompson was charged, along with eighteen co-defendants, with conspiring to distribute heroin, crack cocaine, and buprenorphine in central Pennsylvania. This involved a vast drug distribution network originating in Philadelphia, using rental cars to operate along the I-80 corridor. The network used specific mobile phone numbers for drug deals, and wiretap surveillance captured Thompson arranging transactions. Thompson was arrested near a motel, a base of operations, with co-conspirator Chantel McFarlin, who was found with $2,400 in drug proceeds, and Thompson had $800. McFarlin reported Thompson instructed her to hide the money when police stopped their vehicle. Law enforcement recovered drug paraphernalia, proceeds, and a targeted mobile phone from the scene and motel rooms. Another co-defendant, Alkeisha Edwards, was arrested with heroin and the same targeted phone.

Issue

Should Randy Thompson's trial be severed from his co-defendants' trials under Federal Rule of Criminal Procedure 14(a), given his arguments of improper joinder under Rule 8(b), multiple sub-conspiracies, lack of involvement in all co-conspirator acts, and potential prejudice from a joint trial?

Holding

The court denied Randy Thompson's motion to sever, finding that joinder was appropriate under Federal Rule of Criminal Procedure 8(b) and that Thompson failed to demonstrate clear and substantial prejudice required for severance under Federal Rule of Criminal Procedure 14(a).

Rule

Federal Rule of Criminal Procedure 8(b) permits joinder of defendants if they are alleged to have participated in the same act or series of acts constituting an offense, or in the same conspiracy, even if charged with different acts. This rule is construed liberally, and a conspiracy charge provides a common link. Federal Rule of Criminal Procedure 14(a) allows severance if a defendant is prejudiced by a joint trial, but there is a strong presumption against severance due to the public interest in joint trials. To obtain severance, a defendant must demonstrate clear and substantial prejudice resulting in a manifestly unfair trial, considering factors like the likelihood and exculpatory nature of co-defendant testimony, impeachment potential, and judicial economy.

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