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United States v. Solis

915 F.3d 1172 (2019)

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United States v. Solis

United States Court of Appeals for the Eighth Circuit
915 F.3d 1172 (2019)

  • Written by Heather Whittemore, JD

Facts

Elsa Solis (defendant) was involved in a methamphetamine-trafficking ring. The United States government (plaintiff) charged Solis with conspiring to possess methamphetamine with intent to distribute, possessing methamphetamine with intent to distribute, and misprision of a felony. The federal misprision statute, 18 U.S.C. § 4, provided that a defendant was guilty of misprision if she had knowledge of the commission of a felony and did not report the felony to the federal government. Solis was convicted of the charges. Solis appealed her misprision conviction, arguing that it violated the Fifth Amendment privilege against self-incrimination because reporting the methamphetamine-trafficking ring as required by the misprision statute would have required her to incriminate herself, leading to her prosecution.

Rule of Law

Issue

Holding and Reasoning (Per curiam)

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