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United States v. Machado-Erazo

United States District Court for the District of Columbia
986 F. Supp. 2d 39 (2013)

Written by Sara Rhee, JD

Facts

Noe Machado-Erazo and Jose Martinez-Amaya (defendants) were active members of a gang known as MS-13. MS-13 operated transnationally and had approximately 5,000 members in the greater District of Columbia metropolitan area. Machado-Erazo and Martinez-Amaya were part of a subgroup of MS-13 known as the Normandie clique, which operated out of Maryland. At times, Machado-Erazo and Martinez-Amaya held leadership roles within the organization. A jury found Machado-Erazo and Martinez-Amaya guilty of conspiracy to violate the Racketeer Influenced and Corrupt Organizations (RICO) Act, based on the predicate crimes of murder, extortion, and obstruction of justice. Machado-Erazo and Martinez-Amaya challenged the guilty verdicts, arguing that they could not be liable for the crimes of their alleged coconspirators from other MS-13 cliques because there was no evidence that they agreed to or were involved in such crimes. Machado-Erazo and Martinez-Amaya argued that the prosecution had established the existence of several independent conspiracies within MS-13 rather than a single, overarching conspiracy. Machado-Erazo and Martinez-Amaya filed motions for a judgment of acquittal and a new trial.

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Holding and Reasoning (Lamberth, J.)

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