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United States v. Hall

United States Court of Appeals, Eighth Circuit

December 19, 2019

United States of America Plaintiff-Appellee
Charles Michael Hall Defendant-Appellant

          Submitted: January 15, 2019

          Appeal from United States District Court for the Western District of Missouri - Springfield

          Before LOKEN, GRASZ, and STRAS, Circuit Judges.


         Charles Hall and Wesley Coonce killed Victor Castro-Rodriguez after brutally beating him. A jury found Hall guilty of first-degree murder, see 18 U.S.C. § 1111(b), and following the presentation of a number of aggravating and mitigating factors, returned a death sentence. Hall appeals only his sentence and challenges, among other issues, the aggravating and mitigating factors the jury considered, the evidence it heard, and the instructions it received. We affirm.


         The three men were serving federal sentences in a mental-health ward at a medical center for federal prisoners in Springfield, Missouri, when Hall and Coonce attacked Castro-Rodriguez. As Hall admitted, they had discussed the crime two or three days in advance. Hall has said that killing calms him and that if Castro-Rodriguez had not been available, he "would have randomly selected another inmate" to kill instead.

         According to the testimony of one inmate, Hall lured Castro-Rodriguez by promising him money if he would pretend to be a hostage. Hall allegedly told him that if he would go along, prison officials might agree to give them additional privileges, including cable television, in exchange for his release. After Castro-Rodriguez agreed, Hall and Coonce followed him into his cell, where they made him lie on his back, bound his hands and feet, stuffed a rag in his mouth, and blindfolded him. Once he could no longer move or call for help, Coonce repeatedly kicked him and stomped on his neck. Hall then stood on his throat. After several minutes, Hall stepped off, checked for a pulse, and punched his stomach "to see if he would react." An autopsy revealed that Castro-Rodriguez died from suffocation caused by compression of his larynx, although he also had internal bleeding, scrapes, and bruises from the repeated blows to his head, neck, and chest.

         Hall and Coonce were tried together. The jury found them both guilty after deliberating for less than three hours. At a joint sentencing hearing, the jury heard evidence about various aggravating and mitigating factors. After deliberating again-this time into a second day-the jury unanimously recommended a death sentence for both of them. The district court[1] accepted the jury's recommendation and entered judgment.


         The first question is whether the district court abused its discretion by trying Hall and Coonce together. See United States v. Ortiz, 315 F.3d 873, 898 (8th Cir. 2002). Both initially objected to a joint trial, but after the jury found them guilty, Hall withdrew his objection to a joint sentencing hearing. His position now is that the refusal to sever the proceedings at the guilt phase allowed the jury to hear evidence that unfairly prejudiced him during the penalty phase.

         A joint trial is "often preferable when the joined defendants' criminal conduct arises out of a single chain of events," because it gives the jury a chance "to assign fairly the respective responsibilities of each defendant." Kansas v. Carr, 136 S.Ct. 633, 645 (2016) (citation omitted). This case is a good example. Hall and Coonce agreed ahead of time to murder Castro-Rodriguez. Once they entered his cell together, Hall tied him up, Coonce took the lead in assaulting him, and then Hall dealt the fatal blow by standing on his throat. They acted side by side at every step, so it was logical for the district court to allow "their fates [to be] determined by a single jury." Id. at 646.

         To be sure, holding a joint trial resulted in the same jury hearing both Coonce's guilt-phase defense that Hall was the driving force behind the crime and the government's case for the death penalty. This made the proceeding unfair, according to Hall, because Coonce's theory "logically supported" and supplemented the government's penalty-phase argument that Hall would likely be violent in the future.

         Even if these arguments overlapped to some degree, Hall cannot establish that Coonce's guilt-phase evidence "so infected the sentencing proceeding with unfairness as to render the jury's imposition of the death penalty" unconstitutional. Id. at 644-45 (citation omitted). In arguing that he was less blameworthy than Hall, Coonce never suggested that Hall, as the alleged mastermind, would do something similarly violent in the future. Nor did the government connect those dots. Its theory was simpler: Hall was dangerous because he repeatedly said he would commit crimes and had a lengthy history of threatening violence. See infra Part IV.B (addressing the admissibility of the government's evidence). For us to accept Hall's theory that the joint trial unfairly prejudiced him would require "an exercise in speculation, rather than reasoned judgment." Romano v. Oklahoma, 512 U.S. 1, 14 (1994). And speculation is not enough. See Carr, 136 S.Ct. at 646.


         Hall's next group of challenges focuses on the aggravating and mitigating factors presented to the jury. In determining whether a death sentence was "justif[ied]," the jury's task during the penalty phase was to "consider" whether the aggravating factors "sufficiently outweigh[ed]" the mitigating factors. 18 U.S.C. § 3593(e); see also id. § 3592 (identifying potential aggravating and mitigating factors).


         The federal death-penalty statute divides aggravating factors into two categories: the listed ones that the jury "shall" consider and those "other aggravating factor[s]" that it "may" consider. Id. § 3592(c). Despite this open-ended language, Hall claims that one unlisted factor, grave indifference to human life, should never have been submitted to the jury.[2] He points out that the jury already considered his mental state once in determining that he was eligible for the death penalty, so doing it again improperly counted the same factor twice. The premise is correct, but his conclusion is not.

         Nothing in the federal death-penalty statute says that the jury can only consider a defendant's mental state once. To the contrary, the statute contemplates the possibility that the jury will do so at least twice, first when determining whether the death penalty is on the table at all and again when evaluating the aggravating factors presented by the government. Compare id. § 3591(a)(2) (listing the various mental states giving rise to death-sentence eligibility), with id. § 3592(c)(5) (requiring a "grave risk of death"); id. § 3592(c)(6) (committing the offense in an "especially heinous, cruel, or depraved manner"); id. § 3592(c)(9) (demonstrating "substantial planning and premeditation"); id. § 3592(c)(16) (having the intent to kill or attempting "to kill more than one person in a single criminal episode"). And some of the factors even seem to overlap with one another, further weakening Hall's double-counting theory. See, e.g., id. § 3592(a)(1) (acting with a "significantly impaired" capacity to "appreciate the wrongfulness" of the conduct); id. § 3592(a)(6) (carrying out the offense "under severe mental or emotional disturbance"). Hall's argument, in other words, is contrary to the statute, which constructs a two-stage process with overlapping inquiries, see id. §§ 3591(a)(2), 3592(a), (c), and is inclusive when it comes to the factors that a jury may consider, see id. § 3592(c).


         Hall challenges another aggravating factor for a different reason. He argues that the government did not provide enough evidence for the jury to find that he killed Castro-Rodriguez in an especially heinous, cruel, or depraved manner. See id. § 3592(c)(6).

         In explaining this factor, the district court told the jury that the killing was heinous if it was "extremely wicked or shockingly evil"; it was cruel if Hall "intended to inflict a high degree of pain"; and it was depraved if Hall "relished the killing or showed indifference to [Castro-Rodriguez's] suffering." The government also had to show "serious physical abuse," which the instructions defined as "a significant or considerable amount of injury or damage to [Castro-Rodriguez's] body." See 18 U.S.C. § 3592(c)(6) (requiring "torture" or "serious physical abuse"); see also United States v. Montgomery, 635 F.3d 1074, 1095-96 (8th Cir. 2011) (defining "serious physical abuse" to include "inflict[ing] suffering . . . above and beyond that necessary to cause death" (internal quotation marks and citation omitted)).

         Contrary to Hall's suggestion, the government's evidence was sufficient to find that the killing was heinous, cruel, or depraved, and that it involved the infliction of serious physical abuse. The primary source of the government's evidence was Hall's initial statement to investigators shortly after the murder. In it, he recounted how he had bound Castro-Rodriguez's hands and feet, stuffed a rag in his mouth, blindfolded him, watched Coonce assault him, and then stood on his throat until he stopped breathing. He also acknowledged the senselessness of the crime, explaining that if Castro-Rodriguez had not been available, he "would have randomly selected another inmate and killed him" instead. The medical examiner, after describing the injuries and confirming that they were consistent with ...

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