U.S. v. Waldon
The decision in this case is an affirmation of the United States Court of Appeals of the decision rendered by an inferior court concerning the death sentence of the appellant. The defendant sought the reversal of the death penalty passed on him by relying on some irregularities committed by the grand jury. The appellant claimed the trial judge acted contrary to the language used in the Federal Death Penalty Act (FDPA).
Facts of the Case
Waldon was the deputy sheriff at Jacksonville’s Sheriff Office (JSO). Between 1994 and1997 he served on the SWAT team. In April 1197, Waldon was transferred to the narcotic drugs monitoring unit. Eric Sinclair and Jackson Pough were assigned to the narcotic drug unit. The three were involved in crime a crime spree. They extorted money from drug dealers and other criminals.
Eric Sinclair and Jackson Pough stole money from a bank customer who had withdrawn a large amount of money. Before stealing the money they had trailed the customer and then one of them brandished a gun as the other grabbed the money from the customer. A They stole a total of $ 50000 from the bank customer. Waldon heard about that and was excited about doing a similar deal.
Waldon organized with officer Reginald Bones to steal from another bank customer. They organized together with Kenneth McLaughlin, a convicted felon, how they would conduct the robbery. Officer Bones backed out the last minute, hence the plan was delayed. Waldon, McLaughlin proceeded with the plan. They recruited James Swift, Waldon’s brother in law, to help them execute the robbery.
On 3rd July 1998, they robbed a bank client named Sofar. Waldon was afraid that Sofar had seen his face. He took a rope and used it to choke Sofar who was handcuffed in the back seat. The trio proceeded to dump the body as they had planned. Waldon was arrested and charged with murder. The district court found him guilty and sentenced him to death. Waldon appealed.
Contentions
Waldon sought the reversal of the conviction leveled against him. He brought to the attention of the United States Courts of Appeals his perceived irregularities the grand jury had involved in. Waldon said that an error had occurred when the trial judge failed to stop his grand jury testimony. He argued the language of the Death Penalty Act (DPA) expressly declared that a trial judge had to recommend either death or a life sentence.
Issue(s)
Did the grand jury act in contravention of the grand jury clause in the Fifth Amendment?
Did the government provide evidence to prove that Waldon killed Sofar for personal gain and should he have been convicted of the death penalty?
Decision
The grand jury neither acted in contravention of the Fifth Amendment nor in bad faith. The conviction of Waldon was orderly and according to the law. The government did not need to prove that Waldon murdered Sofar for personal gain since his actions were in bad faith.
Reasoning
There were no errors made by the district court in failing to stop the second indictment in Waldon’s case and those errors cannot apply cannot apply cumulatively to his trial. The grand jury was right in convicting Waldon of the death penalty. The government did not require proving that he murdered Sofar for personal gain for the death penalty to be applied. The government followed the due process set out in the Death Penalty Act.
Rule of Law
The Death Penalty Act required the government to file a case in a court of law and prove that Weldon was guilty which it did. Hence Weldon argument against the grand jury’s actions was based on his own legal errors. The Fifth Amendment did not require the grand jury to stop his conviction because of a later indictment of the defendant.
Reference
U.S. v. Waldon, 363 F.3d 1103 (United States Court of Appeals, Eleventh Circuit March 25, 2004).
