Summary
The Ninth Circuit vacated John Matthew Chapman’s conviction for kidnapping resulting in death under 18 U.S.C. § 1201(a)(1) 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 that sufficient evidence supported the conviction. The court also affirmed the denial of Chapman’s motion to suppress his confession, concluding 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 establish the holding element and the other elements of kidnapping resulting in death under 18 U.S.C. § 1201(a)(1).
- Whether the federal kidnapping statute permits the holding element to be satisfied through nonphysical means, including deception in an inveiglement case.
- Whether the district court improperly coerced the jury's verdict through its Allen charge, nondisclosure of substantive jury notes, questioning of a holdout juror, and related conduct.
- Whether Chapman knowingly and intelligently waived his Miranda rights.
- Whether Chapman's post-Miranda confession was voluntary.
- Whether the district court's jury instruction that deception could satisfy the holding element was legally erroneous.
Holdings
- The holding element of 18 U.S.C. § 1201(a)(1) does not require physical force; in an inveiglement case, a victim may be held against her 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 a new trial.
- Chapman knowingly and intelligently waived his Miranda rights.
- Chapman's post-Miranda statements were voluntary and were not obtained through coercion or an improper inducement.
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.” (17)
“A criminal defendant “being tried by a jury is entitled to the uncoerced verdict of that body.”” (21)
“After being deadlocked for two days during deliberations, the jury spent only thirty-seven minutes deliberating after the district court’s charge before swiftly returning with a unanimous guilty verdict.” (23)
“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)
Factual background
Chapman and Jamie Feden traveled from Pennsylvania to Las Vegas in September 2019. Chapman had searched online about murdering someone and disposing of a body, later drove Feden to a remote Nevada desert, restrained her with zip ties and duct tape, and left her body there after she died. After returning to Pennsylvania, Chapman impersonated Feden through her phone and online accounts, and later confessed during police questioning after receiving Miranda warnings and signing a waiver. During deliberations, the jury sent notes revealing a numerical division and uncertainty, but the district court did not disclose the notes before giving an Allen charge and later questioned an identified holdout juror.
Procedural history
Chapman was charged by complaint and indicted by a grand jury on one count of kidnapping resulting in death under 18 U.S.C. § 1201(a)(1). The district court denied his motion to suppress after a magistrate judge held a hearing and issued a report and recommendation. After an eight-day trial, the jury returned a guilty verdict; the district court denied Chapman's Rule 29 and Rule 33 motions. The Ninth Circuit vacated the conviction and remanded for a new trial, while holding that the evidence was sufficient and the confession was admissible.
Remand instructions
Vacate the kidnapping conviction and remand to the United States District Court for the District of Nevada for a new trial. The sufficiency ruling does not bar retrial, and the confession remains admissible under the appellate ruling.