Tampa Criminal Lawyer Blog
Murder-for-hire prosecutions represent some of the most aggressive uses of federal criminal law, often combining firearms allegations with expansive theories of interstate commerce to impose mandatory life sentences. In these cases, seemingly local acts such as driving a car or exchanging drugs can become the foundation for sweeping federal jurisdiction and extreme punishment. A recent decision from a Florida court demonstrates how courts apply these doctrines to uphold convictions arising from a contract killing carried out entirely within one state. If you are charged with a violent crime, you should consider consulting with an experienced Tampa criminal defense attorney to assess how evidentiary rules may affect your case.
Facts and Procedural History
Allegedly, the defendants were involved in a plot to kill a rival drug dealer in exchange for cash and controlled substances. The government contended that one defendant arranged the killing and paid the others money and cocaine to carry it out, also supplying a firearm to be used in the attack.
Reportedly, the shooting occurred on a public roadway when the defendants pulled alongside the victim’s vehicle and opened fire, killing two occupants and injuring a third. The government asserted that the roadway formed part of a federally designated highway system and that the defendants used a private automobile to carry out the killing.
It is alleged that a federal grand jury returned a superseding indictment charging multiple offenses, including murder-for-hire, conspiracy to distribute controlled substances, and firearms offenses resulting in death. The indictment alleged that the defendants used or caused the use of a facility of interstate commerce to commit murder in exchange for something of value.
It is reported that the defendants proceeded to a lengthy jury trial in federal district court. After the government rested, the defendants moved for judgments of acquittal, arguing that the evidence was insufficient to establish the interstate commerce element of the murder-for-hire statute and that the drug conspiracy charges were unsupported. The district court denied the motions, and the jury returned guilty verdicts on all counts. The court imposed life sentences and additional terms of imprisonment.
Reportedly, the defendants appealed their convictions, challenging the scope of the murder-for-hire statute, the constitutionality of applying it to intrastate conduct, the jury instructions, and the sufficiency of the evidence supporting the drug and firearms convictions.
Evidence in Florida Murder Cases
On appeal, the court reviewed the defendants’ statutory and constitutional arguments de novo while viewing the evidence in the light most favorable to the jury’s verdict. The court first addressed whether the intrastate use of a private automobile satisfied the murder-for-hire statute’s requirement that a facility of interstate commerce be used.
Relying on recent circuit precedent, the court held that automobiles qualify as instrumentalities and facilities of interstate commerce, even when used entirely within a single state. The court emphasized that Congress amended the statute to cover facilities of interstate commerce, not merely facilities used in interstate travel. As a result, the defendants’ use of a car to carry out the killing satisfied the statute’s jurisdictional element.
The court also rejected the defendants’ argument that the statute exceeded Congress’s authority under the Commerce Clause. Applying plain-error review, the court concluded that binding precedent foreclosed any claim that regulating intrastate use of an automobile for murder-for-hire was unconstitutional.
Next, the court addressed the defendants’ challenge to the jury instructions, which argued that the government was required to prove the defendants knowingly used an interstate facility. The court rejected that contention, explaining that prior precedent holds that the statute does not impose a scienter requirement for the commerce element.
Turning to the drug conspiracy charges, the court concluded that sufficient evidence supported the jury’s findings. Testimony established that the defendants received multiple ounces of cocaine as partial payment for the killing, an amount consistent with distribution rather than personal use. The court held that the jury could reasonably infer an agreement to possess and distribute controlled substances.
After reviewing all claims, the court affirmed the convictions and sentences in their entirety.
Speak with a Skilled Tampa Criminal Defense Attorney
If you are charged with a violent crime, it is smart to speak to an attorney to better understand your rights and possible defenses. The skilled Tampa criminal defense attorneys at Hanlon Law understand how federal courts interpret firearm enhancements and conspiracy allegations, and if you hire us, we can evaluate the evidence against you and explain your options. Contact our Tampa office online or call 813-228-7095 to schedule a confidential consultation.