Francisca C. Miller v. United States

Summary

The District of Columbia Court of Appeals held that Francisca Miller was constitutionally entitled to a jury trial because she was charged with offenses that legally authorized her removal from the United States. Applying plain-error review, the court concluded that the denial of her Sixth Amendment jury-trial right affected her substantial rights and the fairness and integrity of the proceedings. The court vacated her convictions for attempted possession of a prohibited weapon and attempted threats to do bodily harm and remanded for further proceedings.

Holdings

1. The evidence was sufficient to support Miller's convictions because, viewed in the light most favorable to the verdict, a rational factfinder could find the essential elements beyond a reasonable doubt, and the appellate court would not disturb supported credibility determinations.
2. Attempted threats to do bodily harm is a legally cognizable offense in the District of Columbia.
3. A defendant charged with an offense that legally authorizes removal from the United States has a Sixth Amendment right to a jury trial.
4. The unpreserved denial of Miller's jury-trial right constituted plain error warranting reversal because the error was obvious, affected her substantial rights, and seriously affected the fairness, integrity, or public reputation of judicial proceedings.

Questions Presented

1. Whether the evidence was sufficient to support convictions for attempted possession of a prohibited weapon and attempted threats to do bodily harm.
2. Whether attempted threats to do bodily harm is a legally cognizable offense in the District of Columbia.
3. Whether Miller had a constitutional Sixth Amendment right to a jury trial because she was charged with offenses that legally authorized her removal from the United States.
4. Whether the unpreserved denial of the jury-trial right satisfied the four-part plain-error standard.

Disposition

vacated