United States v. Love

20 F.4th 407 (8th Cir. 2021)

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Legal Analysis

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Nature Of The Case

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Facts

D was serving a sentence at the U. S. Medical Center for Federal Prisoners in Springfield, Missouri. D entered the room of another inmate and attacked him, causing severe injuries, emergency intubation, and facial reconstruction surgery. D was charged with assault resulting in serious bodily injury at a place within the special maritime and territorial jurisdiction of the United States. P requested judicial notice that the United States has special maritime and territorial jurisdiction over the Center. D claimed that the Sixth Amendment required P to prove this jurisdiction as an element of the offense. Three witnesses testified about the 'federal nature' of the Center. P presented no other evidence about special maritime and territorial jurisdiction. The district court said, based on its extensive historical research about the Center, it would take judicial notice of special maritime and territorial jurisdiction. The court instructed the jury that the Center was within special maritime and territorial jurisdiction. D was convicted and appealed arguing that the district court violated his Sixth Amendment rights by its judicial notice of special maritime and territorial jurisdiction.

Issues

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Holding & Decision

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