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U.S. v. Wicker

United States Court of Appeals, Tenth Circuit
Jun 6, 1988
848 F.2d 1059 (10th Cir. 1988)

Summary

holding that despite absence of bad faith, government's "neglect[]" of its disclosure duty justified district court's conclusion that this factor weighed in favor of defendant

Summary of this case from United States v. Moya

Opinion

Nos. 87-2526, 87-2527.

June 6, 1988.

David N. Williams, Asst. U.S. Atty. for the District of New Mexico (William L. Lutz, U.S. Atty. for the District of New Mexico, with him on the brief), for plaintiff-appellant.

Peter Schoenburg, Federal Public Defender Office, Albuquerque, N.M., for defendant-appellee Wicker.

James Rawley of James Rawley and Associate (Joy Christenberry of James Rawley and Associate, with him on the brief), Albuquerque, N.M., for defendant-appellee Siler.

Appeal from the United States District Court for the District of New Mexico.

Before McKAY and BRORBY, Circuit Judges, and BOHANON, District Judge.

Honorable Luther L. Bohanon, United States Senior District Judge for the District of Oklahoma, sitting by designation.


The issue presented in this case is whether the district court abused its discretion in suppressing the testimony and laboratory report of a government expert as a sanction for the government's failure to comply with a discovery order.

I.

On August 5, 1987, Tony Ray Wicker and Vickie Siler were charged in a four-count superseding indictment with violating 21 U.S.C. § 856 (Supp. IV 1986); 21 U.S.C. § 841(a)(1) (1982); 21 U.S.C. § 841(b)(1)(C) (Supp. II 1982), and 18 U.S.C. § 2 (1982) by (1) renting a room for the purpose of unlawfully manufacturing, storing, distributing, and using methamphetamine; (2) manufacturing methamphetamine; (3) possessing a controlled substance with intent to manufacture phenylacetone; and (4) possessing methamphetamine with intent to distribute.

On August 21, 1987, the district court granted defendants' request, made under Rule 16(a)(1)(D) of the Federal Rules of Criminal Procedure, that the government be required to produce a laboratory and scientific report reflecting the results of tests performed on materials confiscated from the defendants' room. The district court ordered the government to produce the report by September 18, 1987, so the defendants would have sufficient time to review the report and prepare for trial. The government did not produce the report before the deadline. Instead, it was not until October 2, 1987, that Mr. Wicker's counsel received the report and not until October 5, 1987, that Ms. Siler's counsel received the report.

Trial was originally set for August 31, 1987; however, a continuance was granted and trial was rescheduled to begin on October 8, 1987. Apparently, on October 6 or 7 the trial date was changed by the district court to October 13. Record, vol. 5, at 410.

On October 6, 1987, Mr. Wicker filed a motion in limine to prevent the government from introducing into evidence the report or the testimony of the expert who prepared the report. Mr. Wicker claimed that the government's delayed production did not give Mr. Wicker's counsel sufficient time to analyze and rebut either the report or testimony before the trial date. On October 7, 1987, Ms. Siler filed a similar motion to exclude the government's evidence. The district court conducted a hearing by telephone on October 7, 1987, to determine whether the requested sanctions were justified. At the conclusion of this conference, the district court found the sanctions to be warranted and granted defendants' motions. The government now brings an interlocutory appeal to contest the exclusion of the report and the testimonial evidence.

II.

Rule 16(d)(2) of the Federal Rules of Criminal Procedure gives the district court broad discretion in imposing sanctions on a party who fails to comply with a discovery order:

If at any time during the course of the proceedings it is brought to the attention of the court that a party has failed to comply with this rule, the court may order such party to permit the discovery or inspection, grant a continuance, or prohibit the party from introducing evidence not disclosed, or it may enter such other order as it deems just under the circumstances. The court may specify the time, place and manner of making the discovery and inspection and may prescribe such terms and conditions as are just.

Fed.R.Crim.P. 16(d)(2); see also United States v. Evans Associates Construction Co., 839 F.2d 656, 660 (10th Cir. 1988) (the district court has discretion in selecting sanctions for failure to comply with discovery orders); United States v. Fernandez, 780 F.2d 1573, 1576 (11th Cir. 1986) (a district court's imposition of sanctions pursuant to Rule 16(d)(2) will not be disturbed absent abuse of discretion). Despite this broad grant of power, the district court's exercise of discretion should be guided by several factors; and if a sanction is imposed, it should be the "least severe sanction that will accomplish . . . prompt and full compliance with the court's discovery orders." Fernandez, 780 F.2d at 1576 (quoting United States v. Sarcinelli, 667 F.2d 5, 7 (5th Cir. Unit B 1982)).

When the government fails to comply with a discovery order, the factors the district court should consider in determining if a sanction is appropriate are (1) the reasons the government delayed producing the requested materials, including whether or not the government acted in bad faith when it failed to comply with the discovery order; (2) the extent of prejudice to the defendant as a result of the government's delay; and (3) the feasibility of curing the prejudice with a continuance. United States v. Euceda-Hernandez, 768 F.2d 1307, 1312 (11th Cir. 1985); Fernandez, 780 F.2d at 1576.

We note that these three factors should merely guide the district court in its consideration of sanctions; they are not intended to dictate the bounds of the court's discretion. "[A] comprehensive set of standards to guide the exercise of discretion in every possible case" is "neither necessary nor appropriate." Taylor v. Illinois, ___ U.S. ___, 108 S.Ct. 646, 655, 98 L.Ed.2d 798 (1988). On occasion the district court may need to suppress evidence that did not comply with discovery orders to maintain the integrity and schedule of the court even though the defendant may not be prejudiced. See United States v. Campagnuolo, 592 F.2d 852, 858 (5th Cir. 1979) (there is no abuse of discretion when "a district judge for prophylactic purposes suppresses evidence . . . the government should have disclosed earlier"); see also United States v. Carrigan, 804 F.2d 599, 603 (10th Cir. 1986) (district court has "inherent power to control and supervise its own proceedings").

Review of the record reveals that the district court considered each of the Euceda-Hernandez factors in exercising its discretion to exclude the government's evidence. First, the court examined the reasons for the delayed production of evidence. The government never denied that it did not produce the report by September 18, 1987. Rather, the government attempted to explain the delay by claiming that the expert who prepared the report was negligent in failing to send copies of the report to the government as requested. The report was completed on August 28, 1987, and the government asked the expert to send copies of the report to the government once the report was typed. Record, vol. 1, doc. 68, at 1. Apparently, the expert forgot to forward the copies to the government until he was reminded by the government in early October.

Even if the expert were negligent as the government alleges, a single request for the report does not relieve the government of its discovery obligation. Had the government made the least effort to follow up on its request and not neglected its duty under Rule 16(a)(1)(D), a copy would have been delivered to the defendants pursuant to the court's order. Although the district court did not consider whether the government acted in bad faith in not complying with the discovery order, the district court was clearly justified in concluding that the government's reason was not sufficient to justify the delay.

The district court next considered whether the defendants were prejudiced by the late production. The court found that the government may have orally communicated some cursory results of the test to the defendants prior to September 18, 1987. However, the district court was not convinced that this communication satisfied the requirement to produce the laboratory report or that the communication provided all the necessary information the defendants were entitled to for their trial preparation. Nor was the district court convinced that the government's communication was a sufficient basis upon which the defendants could retain an expert to help rebut the government's report. Thus, the district court concluded that the defendants were prejudiced by the government's noncompliance.

The district court lastly considered whether it could remedy the prejudice by granting a continuance to allow defendants time to review and rebut the report. The district court observed that the jury had already been selected and that trial was ready to begin. Moreover, the district court noted that scheduling constraints imposed by other cases on its docket would not allow a continuance without prejudicing the parties in other criminal matters. The district court was also cognizant that it had already taken affirmative steps in this case to guarantee prompt and complete discovery, but to no avail. On August 21, 1987, for example, the district court granted a continuance, reset the trial for October 8, 1987, and imposed various discovery deadlines. All of these actions were designed to help move discovery along so the parties and issues would be ready for trial. Despite these efforts, the parties were not ready for trial on October 7, 1987, because the government had failed to meet the court-ordered deadlines.

A continuance may normally be the most desirable remedy for the government's failure to comply with a discovery order. Here, however, in view of the district court's pressing schedule, the status of the present case, and the failure of a prior continuance and deadlines to ensure timely discovery; the court concluded that a second continuance would not compensate for the prejudice imposed upon the defendants. In light of the district court's consideration of the relevant factors and our review of the record, we cannot say that the district court abused its discretion in suppressing the government's evidence.

The judgment of the district court is AFFIRMED.


Summaries of

U.S. v. Wicker

United States Court of Appeals, Tenth Circuit
Jun 6, 1988
848 F.2d 1059 (10th Cir. 1988)

holding that despite absence of bad faith, government's "neglect[]" of its disclosure duty justified district court's conclusion that this factor weighed in favor of defendant

Summary of this case from United States v. Moya

finding no abuse of discretion where the district judge excluded evidence after finding a continuance was not possible due to “the district court's pressing schedule, the status of the present case, and the failure of a prior continuance and deadlines to ensure timely discovery.”

Summary of this case from United States v. Perez-Espinoza

affirming decision to suppress evidence based on a Rule 16 violation

Summary of this case from U.S. v. Martinez

affirming the district court's decision to impose sanctions because of the Government's bad faith failure to disclose evidence

Summary of this case from U.S. v. Williams

In United States v. Wicker, 848 F.2d 1059 (10th Cir. 1988), we set forth three factors that the district court should consider when determining whether a Rule 16 sanction is appropriate: (1) the reason for the delay, including whether the non-compliant party acted in bad faith; (2) the extent of prejudice to the party that sought the disclosure; and (3) "the feasibility of curing the prejudice with a continuance."

Summary of this case from United States v. Walker

noting that Wicker factors "are not intended to dictate the bounds of the court's discretion"

Summary of this case from United States v. Moya

In United States v. Wicker, 848 F.2d 1059 (10th Cir. 1988), we considered an interlocutory appeal filed by the government challenging a district court order excluding evidence from a criminal trial as a sanction for the government's production of a laboratory and scientific report to the defendants just days prior to the start of trial.

Summary of this case from United States v. Yepa

In Wicker, for example, the district court's decision to exclude evidence (and our affirmance thereof) was driven, in part, by the fact that "the jury had already been selected and th[e] trial was ready to begin."

Summary of this case from United States v. Yepa

distinguishing between the government and an expert employed by the prosecution

Summary of this case from United States v. Yepa

noting that the three identified factors "are not intended to dictate the bounds of the court's discretion"

Summary of this case from United States v. Yepa

noting need in some cases for district court to exclude evidence “to maintain the integrity and schedule of the court”

Summary of this case from United States v. Sims

stating that a court should impose the "least severe sanction"

Summary of this case from U.S. v. Martinez

In Wicker, the court considered three factors: (1) the reason for the delay in disclosing the witness; (2) whether the delay prejudiced the other party; and (3) the feasibility of curing any prejudice with a continuance.

Summary of this case from U.S. v. Adams

noting that factors to be considered — reason for delay, prejudice, and feasibility of curing prejudice with a continuance instead of excluding evidence — were neither exhaustive nor dispositive

Summary of this case from U.S. v. Davis

In Wicker, we approved of the district court's reliance upon three factors to evaluate sanctions imposed on the government for its discovery violations.

Summary of this case from United States v. Gonzales

In Wicker, the court affirmed the district court's decision to bar the government, in a criminal trial, from introducing a report and testimony from the expert who prepared the report.

Summary of this case from U.S. v. Russell

In Wicker, we set out the following factors which the trial court must follow in determining the appropriate sanction for noncompliance of a discovery order.

Summary of this case from U.S. v. Mavrokordatos

In Wicker, the Tenth Circuit outlined three factors that a trial court should consider when determining whether a sanction is appropriate: (1) the reasons the government delayed producing the requested materials, including whether or not the government acted in bad faith; (2) the extent of prejudice to the defendant as a result of the government's delay; and (3) the feasibility of curing the prejudice with a continuance.

Summary of this case from United States v. Montoya

In United States v. Wicker, 848 F.2d 1059 (10th Cir. 1988), the Tenth Circuit set forth three factors that a district court should consider in determining the appropriate sanction for a Rule 16 violation: (1) the reason for the delay, including whether the non-compliant party acted in bad faith; (2) the extent of prejudice to the party that sought the disclosure; and (3) "the feasibility of curing the prejudice with a continuance."

Summary of this case from United States v. Moya

In Wicker, the delay was due to the failure of the government's expert witness to forward a report to the prosecutor, coupled with the prosecutor's failure to follow up his initial request for the report.

Summary of this case from United States v. Yepa

In Wicker, the Tenth Circuit articulated a non-exhaustive list of factors district courts should consider in fashioning an appropriate sanction for a discovery violation: "(1) the reasons the government delayed producing the requested materials, including whether or not the government acted in bad faith when it failed to comply with the discovery order; (2) the extent of prejudice to the defendant as a result of the government's delay; and (3) the feasibility of curing the prejudice with a continuance."

Summary of this case from United States v. Burciaga

noting that "if a sanction is imposed, it should be the least severe sanction that will accomplish prompt and full compliance with the court's discovery orders"

Summary of this case from U.S. v. Ahrensfield

excluding evidence where the Government submitted lab two weeks after court-ordered production date

Summary of this case from U.S. v. Banki
Case details for

U.S. v. Wicker

Case Details

Full title:UNITED STATES OF AMERICA, PLAINTIFF-APPELLANT, v. TONY RAY WICKER AND…

Court:United States Court of Appeals, Tenth Circuit

Date published: Jun 6, 1988

Citations

848 F.2d 1059 (10th Cir. 1988)

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