Summary
The Ninth Circuit vacated John Matthew Chapman’s conviction for kidnapping resulting in death and remanded for a new trial because the district court improperly coerced the jury’s verdict. The court held that the federal kidnapping statute’s holding element may be satisfied through nonphysical means, including deception, and concluded that sufficient evidence supported the conviction. The court also affirmed the denial of Chapman’s motion to suppress his confession, holding that he knowingly and intelligently waived his Miranda rights and that his confession was voluntary.
Topics
Practice areas
Questions Presented
- Whether the evidence was sufficient to support Chapman's conviction for kidnapping resulting in death under 18 U.S.C. § 1201(a)(1).
- Whether the federal kidnapping statute's holding element can be satisfied through nonphysical means, including deception, in an inveiglement case.
- Whether the district court's jury instructions concerning the holding element were legally erroneous.
- Whether the district court impermissibly coerced the jury's verdict by giving an Allen-type charge while knowing the numerical division of the jury and by questioning an identified holdout juror.
- Whether Chapman knowingly and intelligently waived his Miranda rights.
- Whether Chapman's post-Miranda confession was voluntary.
Holdings
- The holding element of 18 U.S.C. § 1201(a)(1) does not require physical force. In an inveiglement case, a person may be held against their will through nonphysical means, including deception.
- The evidence was sufficient for a rational jury to find Chapman guilty of kidnapping resulting in death, and he was not entitled to acquittal as a matter of law.
- The district court impermissibly coerced the jury's verdict, requiring the conviction to be vacated and the case remanded for a new trial.
- Chapman knowingly and intelligently waived his Miranda rights, and his post-Miranda confession was voluntary.
Key quotations
“We now join our sister Circuits who have addressed the issue before us, and hold that the federal kidnapping statute does not require a use of physical force and that an individual may be “held” against their will through means of deception in an inveiglement case.” (19)
“We hold that the district court improperly coerced the jury’s verdict, and so we vacate the verdict and remand for a new trial.” (24)
“We VACATE Chapman’s conviction and REMAND to the district court for a new trial.” (28)
Factual background
John Chapman traveled with Jamie Feden from Pennsylvania to Las Vegas in September 2019 after making internet searches concerning murder and disposal of a body. In a remote Nevada desert, Chapman told Feden they were going for a drive, bound her to a signpost, placed duct tape over her mouth and nose, and she died. Chapman later confessed during questioning after receiving and signing a Miranda waiver. At trial, the jury deliberated for two days, sent notes revealing disagreement and a numerical vote breakdown, received an Allen-type instruction, and returned a unanimous guilty verdict thirty-seven minutes later after the district court intensely questioned an identified holdout juror.
Procedural history
Chapman was charged by complaint and indicted by a grand jury for kidnapping resulting in death under 18 U.S.C. § 1201(a)(1). The district court denied his motion to suppress after a magistrate judge conducted a hearing, and a jury convicted him after an eight-day trial. The district court denied his post-verdict motions for acquittal and a new trial. The Ninth Circuit held that the evidence was sufficient and that the confession was admissible, but vacated the conviction because the district court impermissibly coerced the jury's verdict and remanded for a new trial.
Remand instructions
The conviction is vacated and the case is remanded to the United States District Court for the District of Nevada for a new trial.