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United States v. Love

20 F.4th 407 (2021)

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United States v. Love

United States Court of Appeals for the Eighth Circuit
20 F.4th 407 (2021)

Facts

Earl Love (defendant) was an inmate at the U.S. Medical Center for Federal Prisoners (center), a federal correctional facility located in Springfield, Missouri. He attacked another inmate, causing serious injuries. Love was charged with assault under 18 U.S.C. § 113(a)(6), a federal statute criminalizing assaults within the United States’ special maritime and territorial jurisdiction. For a conviction, the government needed to prove that (1) Love intentionally assaulted another, (2) the other person suffered a serious bodily injury, and (3) the assault occurred within the special maritime and territorial jurisdiction of the United States. The district court resolved the third element by judicial notice, conclusively instructing the jury that the center fell within the United States’ special maritime and territorial jurisdiction, meaning that if the jury concluded the assault occurred at the center, then the third element of the offense was satisfied. Love was convicted. He appealed to the Eighth Circuit, arguing that the judge’s instruction deprived him of his Sixth Amendment right to a jury trial.

Rule of Law

Issue

Holding and Reasoning (Benton, J.)

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