United States v. Riffe
United States Court of Appeals for the Sixth Circuit
28 F.3d 565 (1994)
Leonard Riffe (defendant), an inmate at Michigan’s Standish Correctional Facility (Standish), and his girlfriend, Stephanie Kania, worked together to smuggle marijuana into Standish. Kania received and delivered packages of marijuana to a prison guard, who in turn delivered the packages to Riffe inside the prison. Riffe was consequently convicted of conspiracy to distribute marijuana, as well as aiding and abetting the use of mail to facilitate distribution of marijuana. At trial, Riffe argued that he was under duress from a prison gang to supply the gang with marijuana as repayment of a debt. Riffe presented evidence that the gang members had threatened to kill him if he did not participate in the smuggling activities. Through his own testimony and that of a fellow inmate, Riffe attempted to prove that he had no alternative but to comply with the gang’s demands, as going to prison officials for help would have put him in more danger. Riffe also presented evidence to show that protective segregation in the prison was inadequate and that he would have faced further threats from the other inmates, because the prison officials would have forced him to identify the gang members involved. The district court refused to give an instruction on duress, concluding that Riffe did not meet the five-factor test set forth in United States v. Singleton, 902 F.2d 471 (6th Cir. 1990), because Riffe had not satisfied the third condition of showing that he had no reasonable, legal alternative to violating the law, meaning a chance to refuse to do the criminal act and also to avoid the threatened harm. Despite finding that Riffe reasonably believed he would be subjected to serious consequences if he went to prison officials, the court applied the third factor as a per se rule, refusing a duress instruction unless Riffe could show that he had tried to seek help from the officials. Riffe appealed, arguing that the district court improperly declined to provide the jury with instructions on duress.
Rule of Law
Holding and Reasoning (Merritt, C.J.)
Concurrence/Dissent (Kennedy, J.)
What to do next…
Unlock this case brief with a free (no-commitment) trial membership of Quimbee.
You’ll be in good company: Quimbee is one of the most widely used and trusted sites for law students, serving more than 97,000 law students since 2011. Some law schools—such as Yale, Vanderbilt, Berkeley, and the University of Illinois—even subscribe directly to Quimbee for all their law students. Read our student testimonials.
Learn more about Quimbee’s unique (and proven) approach to achieving great grades at law school.
Quimbee is a company hell-bent on one thing: helping you get an “A” in every course you take in law school, so you can graduate at the top of your class and get a high-paying law job. We’re not just a study aid for law students; we’re the study aid for law students. Read more about Quimbee.
Here's why 176,000 law students have relied on our case briefs:
- Written by law professors and practitioners, not other law students. 14,000 briefs, keyed to 188 casebooks. Top-notch customer support.
- The right amount of information, includes the facts, issues, rule of law, holding and reasoning, and any concurrences and dissents.
- Access in your classes, works on your mobile and tablet. Massive library of related video lessons and high quality multiple-choice questions.
- Easy to use, uniform format for every case brief. Written in plain English, not in legalese. Our briefs summarize and simplify; they don’t just repeat the court’s language.