Summary
The Eighth Circuit affirmed Moreion Lindsey’s convictions and concurrent life sentences for conspiracy to commit murder for hire and murder for hire. The court held that the district court did not abuse its discretion by ordering concealed leg restraints based on Lindsey’s violent criminal history and serious pending charges, and that the restraints decision was adequately justified under Deck v. Missouri.
Topics
Practice areas
Questions Presented
- Whether the district court abused its discretion by ordering Lindsey to wear leg restraints during trial without making more extensive findings.
- Whether Deck v. Missouri required the Government to prove beyond a reasonable doubt that the concealed restraints did not contribute to the verdict.
- Whether the district court improperly delegated the restraints decision to the marshals or deferred to courthouse policy.
Holdings
- The district court did not abuse its discretion in ordering Lindsey restrained because it adequately justified the decision by considering his violent criminal history and serious pending charges, while taking steps to prevent the jury from seeing the restraints.
- Deck's burden-shifting rule did not apply because the district court acted with adequate justification in ordering the restraints.
- The district court exercised its discretion rather than improperly delegating the restraints decision because it relied on Lindsey's criminal history and current charges in addition to referring to marshal consultation and courthouse policy.
Key quotations
“A court acts with adequate justification when it engages in a “particularized inquiry” and reaches a “determination . . . reflect[ing] ‘particular concerns’ related to the ‘special security needs or escape risks’ of the defendant on trial.”” (at 5)
“In sum, we conclude that the district court did not abuse its discretion in ordering Lindsey restrained during his trial, where it considered on the record Lindsey’s violent criminal history and his serious pending charges.” (at 6)
Factual background
Ray Bradley suspected that his nephew, Titus Armstead, had orchestrated the theft of drugs and cash from a drug-trafficking organization's stash house. Bradley recruited Jerome Williams to arrange Armstead's killing, and Williams paid Lindsey $15,000 to commit the murder. Lindsey picked Armstead up in St. Louis, drove him to a park, shot him, and photographed the body with a cell phone. Before trial, the Government sought concealed leg restraints based on Lindsey's violent criminal history and the seriousness of the charged murder-for-hire offenses.
Procedural history
A federal grand jury indicted Lindsey for conspiracy to commit murder for hire and murder for hire. A jury convicted him on both counts, and the Eastern District of Missouri sentenced him to two concurrent life sentences. The Eighth Circuit affirmed.