No. 93-7118

IN THE UNITED STATES COURT OF APPEALS
FOR THE TENTH CIRCUIT

        

UNITED STATES OF AMERICA,
Plaintiff-Appellee,

v.

JOHN J. McCULLAH,
Defendant-Appellant.

Appeal from the United States District Court
for the Eastern District of Oklahoma
Honorable Frank H. Seay, Chief Judge
(District Court No. CR-92-32-S)

 

BRIEF OF APPELLANT

ORAL ARGUMENT REQUESTED

Gary Peterson
211 N. Robinson, Suite 1601
Oklahoma City, Oklahoma 73102-7127
(405) 236-8911

Stephen J. Greubel
Stephen J. Knorr
Office of the Federal Public Defender
One West Third
Williams Tower One, Suite 1225
Tulsa, Oklahoma 74103
(918) 581-7656
Attorneys for Appellant

 

TABLE OF CONTENTS

TABLE OF AUTHORITIES

I. STATEMENT OF JURISDICTION

II. STATEMENT OF THE ISSUES PRESENTED FOR REVIEW

III. STATEMENT OF THE CASE

A. Nature of the Case, Course of Proceedings, and Disposition Below

B. Facts Relevant to the Issues Presented For Review

1. The Arvizu Drug Organization: Its Alleged Personnel and Activities

2. The Stolen Arvizu Drug Shipment: Ford and Rogers Come Under Suspicion

3. Arvizu's First Trip to Oklahoma, and the Abortive Plots Against Ford and Rogers

4. Arvizu's Second Trip to Oklahoma

a. Wiscowiche Drives the Pistoleros to Oklahoma, and Meets Arvizu

b. Molina Drives Sanchez, Mendoza and McCullah to Oklahoma

c. Arvizu Assembles the Group at His Oklahoma Lake House

d. Preparations for Arvizu's Renewed Operation Against Rogers

5. The Homicide and Its Aftermath

a. Arvizu, Hutching and Molina Establish Alibis

b. Wiscowiche Takes Charge at the Lake House

c. The Homicide

d. Rogers Delays Calling Police; Collins' Body Is Discovered

e. Rogers Lies to Oklahoma Investigators

f. Arvizu Plots to Kill Mr. McCullah.

6. The Investigations.

a. California Investigators Focus on the Arvizu Organization

b. Lozano Becomes an FBI Informer

c. California Authorities Raid Arvizu's Operations; Arvizu Flees to Mexico

d. Wiscowiche Becomes an FBI Informer

e. Shiew Becomes an FBI Informer in Oklahoma.

f. Surveillance and Arrest of Hutching in Oklahoma

7. The Prosecutions

a. Oklahoma and California Prosecutors Battle for Control of the Case

b. The Government's Bid for the Death Penalty

c. Appointment of Counsel and Preparation for Trial

d. Mendoza Becomes a Government Witness

8. The Trial

a. The Guilt Phase

b. The Penalty Phase

i. The Hutching and Molina Penalty Cases

ii. The McCullah Penalty Case

IV. SUMMARY OF ARGUMENT

Appointment of Counsel

Counsel's Conflict of Interest

Coerced Admissions

Insufficient Evidence on Count 16

Insufficient Evidence on Count 1 Conviction and Sentence

Multiplicity of Counts 1 and 16

Insufficient Evidence on Counts 13 and 14

Error in Overruling Challenge for Cause

Adoption of Codefendants' Arguments

Non-Statutory Aggravating Factors

Statutory Aggravating Factors

Exclusion From Codefendants' Penalty Phases

Serial Penalty Phases Before the Same Jurors

Rule 30 Violation

Prosecutors' Penalty Phase Arguments

Failure to Find Mitigating Factors

Inadequate Penalty Voir Dire

Disproportionate Sentence

Method of Execution

V. ARGUMENT -- GUILT PHASE AND NON-CAPITAL SENTENCING ISSUES

A. THE DISTRICT COURT ERRED IN ITS ASSIGNMENT OF APPOINTED COUNSEL TO MR. McCULLAH

1. Standard of Review

2. The District Court Erred in Denying Appoint­ment of Additional Counsel to Represent Mr. McCullah

a. The Initial Appointment of Counsel for Mr. McCullah, and Disposition of the Motion for Appointment of Additional Counsel

b. The District Court Erred in Refusing to Appoint Trial Counsel Having Capital Punishment Expertise for Mr. McCullah

c. The District Court's Duty to Appoint a Second Counsel Could Not Be Delegated to the Federal Public Defender

d. The Failure to Assign Two Counsel Learned in the Law Was Prejudicial

3. The District Court Erred in Refusing to Permit Defense Counsel to Withdraw Because of Their Office's Representation of a Prospective Government Witness Against Mr. McCullah

a. The Tulsa Federal Public Defenders Were Disqualified From Representing Mr. McCullah

b. The Unresolved Prospect of Emberson's Trial Testi­mony Threatened Defense Counsel's Professional Judgment on Behalf of Mr. McCullah

B. THE DISTRICT COURT ERRED IN ADMITTING STATEMENTS COERCED FROM MR. McCULLAH BY A GOVERNMENT AGENT

1. Standard of Review

2. Circumstances of the Admissions

a. The FBI's Preparations for the Monitored Lozano-McCullah Conversations

b. Lozano Reveals That Mr. McCullah Is to Be Killed by the Arvizu Organization

c. Heroin Is Bought for Mr. McCullah with the FBI's Cash

d. More Death Threats Are Communicated to Mr. McCullah, and Admissions Are Obtained

e. The Prosecution's Use of the Lozano-McCullah Conversations at Trial

3. The Admissions Were Coerced

4. The Error in Admitting the Coerced Statements to Lozano the Was Prejudicial

C. THE HOMICIDE CONVICTION IMPOSED ON COUNT 16 WAS UNSUPPORTED BY SUFFICIENT EVIDENCE

1. Standard of Review

2. Mr. McCullah Lacked the Knowledge of the Arvizu Drug Enterprise Needed to "Work in Furtherance of" That Enterprise

3. The Homicide of Collins Was Not in Furtherance of the Arvizu Drug Enterprise

D. THE CONVICTIONS AND SENTENCES IMPOSED ON COUNTS 1, 13 AND 14 CANNOT BE UPHELD

1. Standards of Review

2. The Conspiracy Conviction Imposed on Count 1, and the Accompanying Sentence, Cannot Stand

a. There was Insufficient Evidence of Mr. McCullah's Knowing Membership in the Arvizu Drug Conspiracy

b. The Conviction Imposed on Count 1 Is Multiplicitous of the Conviction Imposed on Homicide Count 16

c. The Drug Quantity Used for Sentencing on Count 1 Was Clearly Erroneous

3. The Convictions on Counts 13 and 14 Were Unsupported by Sufficient Evidence

E. THE DISTRICT COURT ERRED IN OVERRULING THE DEFENSE'S CHALLENGE FOR CAUSE OF A JUROR WHO WORKED AS A PRISON GUARD

F. THE ARGUMENTS OF MR. McCULLAH'S CODEFENDANTS ARE ADOPTED

 

VI. ARGUMENT -- PENALTY PHASE AND CAPITAL SENTENCING ISSUES

A. THE DISTRICT COURT ERRED IN ITS SUBMISSION OF NON-STATUTORY AND STATUTORY AGGRAVATING FACTORS TO MR. MCCULLAH'S JURY

1. Standards of Review

2. Non-Statutory Aggravating Factors Were Erroneously Submitted to Mr. McCullah's Jury

a. "Use of a Deadly Weapon" Was Not a Valid Non-Statutory Aggravating Factor in a Homicide Case

i. The Deadly Weapon Factor Fails to Meet Statutory Requirements, Because It Did Not "Aggravate" the Homicide

ii. Submission of the Deadly Weapon Factor Violated the Eighth Amendment, Because It Did Not Narrow the Class of Death-Eligible Defendants

iii. Because Mr. McCullah's Jury Weighed an Invalid Non-Statutory Aggravating  Factor, the Judgment on Count 16 Cannot Be Upheld

b. "Commission of the Charged Offenses" Was Not a Valid Non-Statutory Aggravating Factor

i. "Commission" of a ' 848(e)(1)(A) Violation Did Not "Aggravate" the Selfsame § 848(e)(1)(A) Violation

ii. "Commission" of the ' 848(e)(1)(A) Offense Duplicated the Statutory Aggravating Subfactor Defined by § 848(n)(1)(C)

iii. The "Commission" Factor Permitted Duplicative and Improper Consideration of the Non-Homicide Counts

c. The Supposed Failure of Rehabilitative Efforts Was Neither a Valid Nor a Supported Non-Statutory Aggravating Factor

d. The Executive's Authority to Define Non-Statutory Aggravating Factors Is the Product of an Unconsti­tutional Delegation of Legislative Power

3. Statutory Aggravating Factors Were Erroneously Submitted to Mr. McCullah's Jury

a. Weighing of the § 848(n)(1) Subfactors Was Error

i. Weighing of the (n)(1) Factor in the Selection Phase of a Capital Sentencing Violates the Eighth Amendment

ii. Congress Did Not Intend For the (n)(1) Statutory Factor to Be Used In the Selection Phase of Capital Sentencing Under § 848

iii. Even if Weighing of the (n)(1) Statutory Factor Were Lawful, the District Court Erred in Allowing Cumulative Weighing of Both the (n)(1)(C) and (n)(1)(D) Subfactors

b. The "Substantial Planning and Premeditation" Statutory Aggravating Factor Was Submitted in Error

i. The § 848(n)(8) Factor Was Submitted Under Erroneous Instructions Which Failed to Cure the Ambiguity of the Statutory Language

ii. There Was Insufficient Evidence of Substantial Planning of the Offense Charged in Count 16

c. Submission of the "Pecuniary Gain" Statutory Aggravating Factor Was Error

B. THE DISTRICT COURT ERRED IN ITS CHOICE OF A PENALTY STAGE TRIAL FORMAT

1. Standard of Review

2. Holding Trial Proceedings in Mr. McCullah's Absence Violated Both the Constitution and the Federal Rules

a. A Capital Defendant Is Entitled to Attend All Courtroom Proceedings Held Before the Jurors Who Will Decide His Fate

b. Mr. McCullah Did Not Effectively Waive the Right to Be Present, If That Right Was Subject to Waiver

3. The Trial Format Improperly Allowed Interim Jury Deliberations About Mr. McCullah's Culpability and Punishment Before His Case in Mitigation Had Been Heard

C. THE DISTRICT COURT ERRED BY SUBMITTING A NEW AGGRAVATING FACTOR AFTER DEFENSE COUNSEL HAD DELIVERED HIS CLOSING ARGUMENT FOR HIS CLIENT'S LIFE

D. THE PROSECUTION'S DEATH PENALTY ARGUMENTS INACCU­RATELY INFLATED THE EXTENT OF MR. McCULLAH'S CULPABILITY

E. JURORS ERRED IN FAILING TO FIND MITIGATING FACTORS WHICH HAD BEEN ESTABLISHED BY UNCONTRADICTED EVIDENCE

F. THE DISTRICT COURT UNLAWFULLY RESTRICTED VOIR DIRE INQUIRY INTO JURORS' ABILITY TO CONSIDER MITIGATING FACTORS

G. BECAUSE OF PROCEDURAL ERRORS AND DISPROPORTIONALITY, THE DEATH SENTENCE IS ARBITRARY

H. THE SENTENCE OF DEATH BY INTRAVENOUS LETHAL INJECTION IS UNLAWFUL

VII. STATEMENT REGARDING ORAL ARGUMENT

VIII. CONCLUSION

 

 

TABLE OF AUTHORITIES

 

Allen v. District Court,184 Colo. 202, 519 P.2d 351 (1974)

Arave v. Creech,507 U.S. ___, 113 S.Ct. 1534 (1993)

Arizona v. Fulminante,499 U.S. 279 (1991)

Beam v. Paskett,3 F.3d 1301 (9th Cir. 1993), cert. denied,114 S.Ct. 1631 (U.S. 1994)

Bowen v. Georgetown University Hospital, 488 U.S. 204 (1988)

Brooks v. Tennessee,406 U.S. 605 (1972)

Chesapeake & Ohio Ry. Co. v. Martin,283 U.S. 209 (1931)

Clemons v. Mississippi,494 U.S. 738 (1990)

Commonwealth v. Gibbs,533 Pa. 539, 626 A.2d 133 (1993)

Commonwealth v. Westbrook,484 Pa. 534, 400 A.2d 160 (1979)

Cook v. State,369 So.2d 1251 (Ala. 1978)

Crosby v. United States,506 U.S. ___, 113 S.Ct. 748 (1993)

Cross v. United States,325 F.2d 629 (D.C. Cir. 1963)

Diaz v. United States,223 U.S. 442 (1912)

Edward J. DeBartolo Corp. v. Florida Gulf Coast Building & Construction Trades Council,485 U.S. 568 (1988)

Elledge v. State,346 So.2d 998 (Fla. 1977)

Engberg v. Meyer,820 P.2d 70 (Wyo. 1991)

Espinosa v. Florida,505 U.S. ___, 112 S.Ct. 2926 (1992)

Geralds v. State,601 So.2d 1157 (Fla. 1992)

Gladden v. Unsworth,396 F.2d 373 (9th Cir. 1968)

Hansen v. Haff,291 U.S. 559 (1934)

Herrera v. First Northern Savings & Loan Ass'n,805 F.2d 896 (10th Cir. 1986)

Herring v. New York,422 U.S. 853 (1975)

Holloway v. Arkansas,435 U.S. 475 (1978)

Hurd v. American Hoist & Derrick Co.,734 F.2d 495 (10th Cir. 1984)

Iglesias v. United States,848 F.2d 362 (2nd Cir. 1988)

In re Grand Jury Subpoenas,40 F.3d 1096 (10th Cir. 1994)

In re Kemmler,136 U.S. 436 (1890)

In re Medley,134 U.S. 160 (1890)

Jeffers v. United States,432 U.S. 137 (1977)

Johnson v. Mississippi,486 U.S. 578 (1988)

Ladner v. State,584 So.2d 743 (Miss.), cert. denied,502 U.S. 1015 (1991)

Lankford v. Idaho,500 U.S. 110 (1991)

Larson v. Tansy,911 F.2d 392 (10th Cir. 1990)

Lego v. Twomey,404 U.S. 477 (1972)

Loveless v. United States,260 F.2d 487 (D.C. Cir. 1958)

Lowenfield v. Phelps,484 U.S. 231 (1988)

Miller v. Pate,386 U.S. 1 (1967)

Mills v. State,222 Ind. 312, 53 N.E.2d 779 (1944)

Mistretta v. United States,488 U.S. 361 (1989)

Morgan v. Illinois,504 U.S. ___, 112 S.Ct. 2222 (1992)

Murray v. Giarratano,492 U.S. 1 (1989)

Parsons v. Barnes,871 P.2d 516 (Utah 1994)

People v. Dyer,45 Cal.3d 26, 753 P.2d 1, 246 Cal. Rptr. 209, cert. denied, 488 U.S. 934 (1988)

Pierce v. Underwood,487 U.S. 552 (1988)

Pinkerton v. United States,328 U.S. 640 (1946)

Powell v. Alabama,287 U.S. 45 (1932)

Proffitt v. Wainwright,685 F.2d 1227 (11th Cir. 1982), cert. denied,464 U.S. 1002 (1983)

Provence v. State,337 So.2d 783 (Fla. 1976), cert. denied,431 U.S. 969 (1977)

Pulley v. Harris,465 U.S. 37 (1984)

Rock v. Arkansas,483 U.S. 44 (1987)

Rogers v. United States,422 U.S. 35 (1975)

Rosales-Lopez v. United States,451 U.S. 182 (1981)

Rosenwald v. United States,898 F.2d 585 (7th Cir. 1990)

Sandstrom v. Montana,442 U.S. 510 (1979)

Selsor v. Kaiser,22 F.3d 1029 (10th Cir. 1994)

Smith v. State,819 P.2d 270 (Okla. Crim. App. 1991), cert. denied,112 S.Ct. 2312 (U.S. 1992)

Smith v. United States,508 U.S. ___, 113 S.Ct. 2050 (1993)

Snyder v. State,738 P.2d 548 (Okla. Crim. App. 1987)

State v. Davis,38 Ohio St.3d 361, 528 N.E.2d 925 (1988), cert. denied,488 U.S. 1034 (1989)

State v. Diddlemeyer,296 S.C. 235, 371 S.E.2d 793 (1988)

State v. Green,61 N.C. App. 1, 301 S.E.2d 920, aff'd,309 N.C. 623, 308 S.E.2d 326 (1983)

State v. Heidmous,75 N.C. App. 488, 331 S.E.2d 200 (1985)

State v. Quesinberry,319 N.C. 228, 354 S.E.2d 446 (1987)

State v. Stewart,162 N.J. Super. 96, 392 A.2d 234 (1978)

State v. Torrence,305 S.C. 45, 406 S.E.2d 315 (1991)

State v. Westmoreland,314 N.C. 442, 334 S.E.2d 223 (1985)

Stringer v. Black,503 U.S. ___, 112 S.Ct. 1130 (1992)

Taylor v. Illinois,484 U.S. 400 (1988)

Tison v. Arizona,481 U.S. 137 (1987)

Touby v. United States,500 U.S. 160 (1991)

Tuilaepa v. California,512 U.S. ___, 114 S.Ct. 2630 (1994)

Turner v. Safley,482 U.S. 78 (1987)

Turner v. State,340 So.2d 132 (Fla. App. 1976)

United States v. Aceves-Rosales,832 F.2d 1155 (9th Cir. 1987), cert. denied,484 U.S. 1077 (1988)

United States v. Ainesworth,716 F.2d 769 (10th Cir. 1983)

United States v. Allsup,566 F.2d 68 (9th Cir. 1977)

United States v. Anderson,981 F.2d 1560 (10th Cir. 1992)

United States v. Austin,786 F.2d 986 (10th Cir. 1986)

United States v. Bedonie,913 F.2d 782 (10th Cir. 1990), cert. denied,501 U.S. 1253 (1991)

United States v. Bradley,___ F. Supp. ___, No. 1:CR-92-200(M.D. Pa. May 3, 1994)

United States v. Brown,996 F.2d 1049 (10th Cir. 1993)

United States v. Cardall,885 F.2d 656 (10th Cir. 1989)

United States v. Carter,576 F.2d 1061 (3rd Cir. 1978)

United States v. Chalan,812 F.2d 1302 (10th Cir. 1987), cert. denied,488 U.S. 983 (1988)

United States v. Chandler,996 F.2d 1073 (11th Cir. 1993), cert. denied,114 S.Ct. 2724 (U.S. 1994)

United States v. Collins,920 F.2d 619 (10th Cir. 1990), cert. denied,500 U.S. 920 (1991)

United States v. Companion,508 F.2d 1021 (9th Cir. 1974)

United States v. Cook,45 F.3d 388 (10th Cir. 1995)

United States v. Cooper,19 F.3d 1154 (7th Cir. 1994)

United States v. Dumas,688 F.2d 84 (10th Cir. 1982)

United States v. Eagan,965 F.2d 887 (10th Cir. 1992)

United States v. Earley,816 F.2d 1428 (10th Cir. 1987) (in banc)

United States v. Erb,596 F.2d 412 (10th Cir.), cert. denied,444 U.S. 848 (1979)

United States v. Evans,970 F.2d 663 (10th Cir. 1992), cert. denied,113 S.Ct. 1288 (U.S. 1993)

United States v. Franklin,700 F.2d 1241 (10th Cir. 1983)

United States v. Garza, No. CR-B-93-009 (S.D. Tex.), appeal pending, No. 93-7662 (5th Cir.)

United States v. Gaskins,849 F.2d 454 (9th Cir. 1988)

United States v. Gillis,942 F.2d 707 (10th Cir. 1991)

United States v. Haddon,927 F.2d 942 (7th Cir. 1991)

United States v. Hardy,895 F.2d 1331 (11th Cir. 1990)

United States v. Hooks,780 F.2d 1526 (10th Cir.), cert. denied,475 U.S. 1128 (1986)

United States v. Hudson and Goodwin,7 Cranch 32 (U.S. 1812)

United States v. Iorizzo,786 F.2d 52 (2nd Cir. 1986)

United States v. Jones,808 F.2d 754 (10th Cir. 1987)

United States v. Kelly,1 F.3d 1137 (10th Cir. 1993)

United States v. Killip,819 F.2d 1542 (10th Cir.), cert. denied,484 U.S. 865, 987 (1987)

United States v. McIntyre,836 F.2d 467 (10th Cir. 1987)

United States v. Mendoza,473 F.2d 697 (5th Cir. 1973)

United States v. Mendoza-Lopez,481 U.S. 828 (1987)

United States v. Mendoza-Salgado,964 F.2d 993 (10th Cir. 1992)

United States v. Moore,846 F.2d 1163 (8th Cir. 1988)

United States v. Morehead,959 F.2d 1489, aff'd on rehearing in banc,971 F.2d 1461 (10th Cir. 1992)

United States v. Nall,949 F.2d 301 (10th Cir. 1991)

United States v. Nell,526 F.2d 1223 (5th Cir. 1976)

United States v. Olano,507 U.S. ___, 113 S.Ct. 1770 (1993)

United States v. Padilla,947 F.2d 893 (10th Cir. 1991)

United States v. Pitera,795 F. Supp. 546 (E.D.N.Y. 1992)

United States v. Pretlow,779 F. Supp. 758 (D.N.J. 1991)

United States v. Pritchett,470 F.2d 455 (D.C. Cir. 1972)

United States v. Protex Industries, Inc.,874 F.2d 740 (10th Cir. 1989)

United States v. Roane, Tipton and Johnson, No. 3-92-CR-68 (E.D. Va.), appeal pending,Nos. 93-4005, 93-4006, 93-4007, 93-4009, 93-4010 (4th Cir.)

United States v. Robertson, No. 93-1292 (10th Cir. Jan. 23, 1995)

United States v. Sanchez,914 F.2d 1355 (9th Cir. 1990), cert. denied,499 U.S. 978 (1991)

United States v. Shabani, 513 U.S. ___, 115 S.Ct. 382 (1994)

United States v. Shepherd, 576 F.2d 719 (7th Cir.), cert. denied,439 U.S. 852 (1978)

United States v. Smith, 629 F.2d 650 (10th Cir.), cert. denied,449 U.S. 994 (1980)

United States v. Smith, 919 F.2d 123 (10th Cir. 1990)

United States v. Stallings, 810 F.2d 973 (10th Cir. 1987)

United States v. Swafford, 766 F.2d 426 (10th Cir. 1985)

United States v. Villarreal, No. 9:91-CR-4 (E.D. Tex.), aff'd,963 F.2d 725 (5th Cir. 1992)

United States v. Wall, 37 F.3d 1443 (10th Cir. 1994)

United States v. Wander, 601 F.2d 1251 (3rd Cir. 1979)

United States v. Watson, 496 F.2d 1125 (4th Cir. 1973)

United States v. Weichert, 836 F.2d 769 (2nd Cir. 1988)

United States v. Wexler, 838 F.2d 88 (3rd Cir. 1988)

United States v. Winkle, 722 F.2d 605 (10th Cir. 1983)

United States v. Youngpeter, 986 F.2d 349 (10th Cir. 1993)

Vasey v. Martin Marietta Corp., 29 F.3d 1460 (10th Cir. 1994)

Victor v. Nebraska, 511 U.S. ___, 114 S.Ct. 1239 (1994)

Whalen v. United States, 445 U.S. 684 (1980)

Wilkerson v. Utah, 99 U.S. 130 (1878)

Willie v. State, 585 So.2d 660 (Miss. 1991)

Wood v. Georgia, 440 U.S. 261 (1981)

Zant v. Stephens, 462 U.S. 862 (1983) 1

Zuchel v. City and County of Denver, 997 F.2d 730 (10th Cir. 1993)

 

Constitutional Provisions

United States Constitution [MARK 2]  

Article I, § 9
Article III
Amendment V
Amendment VI
Amendment VIII passim

 

Statutes

United States Code [MARK 3]  

2 U.S.C. § 288(a)
2 U.S.C.
§ 288(b)
5 U.S.C.
§ 706(2)(A)
18 U.S.C.
§ 371
18 U.S.C.
§ 1958(a)
18 U.S.C.
§ 3005
18 U.S.C.
§ 3231
18 U.S.C.
§ 3566 (1983)
18 U.S.C.
§ 3591(a)(2)
18 U.S.C.
§ 3592(b)
18 U.S.C.
§ 3592(c)
18 U.S.C.
§ 3592(d)
18 U.S.C. § 3593(e)
18 U.S.C. § 3596(a)
18 U.S.C.
§ 3742(a)
18 U.S.C.
§ 3742(a)(1)
21 U.S.C.
§ 846
21 U.S.C.
§ 848
21 U.S.C.
§ 848(c)
21 U.S.C. § 848(e)(1)
21 U.S.C.
§ 848(e)(1)(A)
21 U.S.C. § 848(h)(1)(B)
21 U.S.C.
§ 848(j)
21 U.S.C.
§ 848(k)
21 U.S.C.
§ 848(m)
21 U.S.C.
§ 848(m)(8)
21 U.S.C.
§ 848(n)
21 U.S.C.
§ 848(n)(1)
21 U.S.C.
§ 848(n)(1)(C)
21 U.S.C.
§ 848(n)(1)(D)
21 U.S.C.
§ 848(n)(6)
21 U.S.C.
§ 848(n)(7)
21 U.S.C.
§ 848(n)(8)
21 U.S.C.
§ 848(q)
21 U.S.C.
§ 848(q)(1)
21 U.S.C.
§ 848(q)(2)
21 U.S.C.
§ 848(q)(3)
21 U.S.C.
§ 848(q)(3)(A)
21 U.S.C.
§ 848(q)(3)(B)
21 U.S.C.
§ 848(q)(5)
21 U.S.C.
§ 848(q)(7)
28 U.S.C.
§ 505
28 U.S.C.
§ 1291
28 U.S.C.
§ 1651(a)
28 U.S.C.
§ 1863(b)(6)(B)
42 U.S.C.
§ 1971(f)

United States Statutes at Large [MARK 13]

Crimes Act of 1790, 1 Stat. 112, § 29 (1790)
Public Law 103-322, Title VI,
§ 60026, 108 Stat. 1982 (1994)
Public Law No. 98-473, Title II, ch. II,
§ 212(a)(2), 98 Stat. 1987 (1984)

Oklahoma Statutes  [MARK 4]

21 Okla. Stat. § 648(A) (1991)
22 Okla. Stat.
§ 1014(A) (1991)
57 Okla. Stat.
§ 510(3) (1991)

 

Rules, Regulations and Guidelines

Federal Rules of Criminal Procedure [MARK 7 and 9]

Rule 1
Rule 14
Rule 24(b)
Rule 29.1
Rule 30
Rule 43
Rule 43(a)
Rule 43(b)
Rule 43(b)(1)
Rule 52(b)
Proposed Amendments to Federal Rules of Criminal Procedure, 62 F.R.D. 271 (1974)

Federal Rules of Evidence [MARK 14]  

Rule 402
Rule 403
Rule 801(d)(2)(E)

Local Rules, Eastern District of Oklahoma [MARK 12]

Rule 4(j)
Rule 31(H)(2)

United States Sentencing Guidelines [MARK 5]

§ 1B1.3(a)(1)(B)
§ 2D1.1(a)(3)
§ 2E1.4(a)(2)

Code of Federal Regulations [MARK 15]  

28 C.F.R. § 26.3(a)(4) 162

American Bar Association, Model Code of Professional Responsibility (1980) [MARK 11]

DR 4-101(B)
DR 5-105(A)
DR 5-105(D)

Other Authorities  [MARK 8]  

American Bar Association Standing Committee on Ethics and Professional Responsibility, Informal Opinion 1418 (Aug. 14, 1978)

Black's Law Dictionary (6th ed. 1990)

Congressional Record,134 Cong. Rec. S7490 (June 9, 1988)

Mauet, Fundamentals of Trial Techniques (2nd ed. 1988)

Note, The Eighth Amendment and Ineffective Assistance of Counsel in Capital Trials,107 Harv. L. Rev. 1923 (1994)

Random House Unabridged Dictionary (2nd ed. 1993)

Sutherland, Statutory Construction Vol. 2A, § 47.33 (5th ed. 1992)

 

PRIOR AND RELATED APPEALS

United States v. Molina, No. 93-7040 (10th Cir.), pending
United States v. Sanchez, No. 93-7042 (10th Cir.), pending
United States v. Hutching, No. 93-7043 (10th Cir.), pending

 

I. STATEMENT OF JURISDICTION.

The District Court's jurisdiction in this criminal case was based on 18 U.S.C. § 3231.

This Court's jurisdiction is based on 28 U.S.C. § 1291, 18 U.S.C. § 3742(a), and 21 U.S.C. § 848(q)(1). A notice of appeal was filed on November 19, 1993 (V.6, Doc. 630),[1]to review judgments and sentences entered on November 12, 1993. See Appendix T and Appendix U.

 

II. STATEMENT OF THE ISSUES PRESENTED FOR REVIEW.

A. Did the District Court err in refusing to appoint defense counsel with capital punishment expertise, when the applicable statute required appointment of two counsel "learned in the law"?

B. Did the District Court err in refusing to allow appointed defense counsel to withdraw, when another client in counsel's office had been identified as a prosecution witness against Mr. McCullah?

C. Did the District Court properly admit evidence of statements by Mr. McCullah to a Government agent, when those statements were provoked by threats of death communicated by the agent?

D. Was there sufficient evidence that Mr. McCullah was "working in furtherance" of a continuing criminal enterprise, as charged in homicide count 16, when he had no involvement in or knowledge of the enterprise's drug trafficking activities?

E. Was there sufficient evidence that the count 16 homicide occurred was "in furtherance of" a continuing criminal enterprise, when that homicide frustrated, rather than furthered, the enterprise's objectives?

F. Was there sufficient evidence to support Mr. McCullah's conviction and sentence for the drug conspiracy alleged in count 1?

G. Was the drug conspiracy alleged in count 1 a lesser included offense of a homicide in furtherance of a continuing criminal enterprise, as charged in count 16, thereby precluding conviction on both counts?

H. Was there sufficient evidence that Mr. McCullah intended commission a murder for hire when he travelled from California to Oklahoma, as required to sustain convictions on counts 13 and 14?

I. Did the District Court properly overrule a challenge for cause against a prospective juror who worked as a correctional officer, when that officer was vested with police powers under state law?

J. Did the District Court err in its submission of non-statutory and statutory aggravating factors to Mr. McCullah's jury?

K. Did the District Court err in holding four days of the penalty phase of the trial in Mr. McCullah's absence?

L. Did the District Court err in adopting a penalty stage format which required jurors to deliberate about Mr. McCullah's relative culpability and punishment before hearing his mitigating evidence?

M. Was it proper to submit a new aggravating factor to a Mr. McCullah's jury, when defense counsel was not advised that the factor was in issue until after his penalty phase closing argument?

N. Did the prosecutor's penalty phase jury argument constitute plain error, when it asserted unsupported facts concerning Mr. McCullah's involvement, which had not been proven in court?

O. When the expert testimony supporting several defense mitigating factors was uncontradicted, did Mr. McCullah's jurors err in refusing to find these factors?

 P. Did the District Court improperly restrict voir dire inquiry into whether prospective jurors would be willing to consider specific mitigating factors at issue in the case?

Q. Was Mr. McCullah's death sentence unlawfully dispro­portionate to those imposed in this and other cases?

R. Did the District Court properly sentence Mr. McCullah to die by lethal injection, when no statute authorized this punishment?

 

III. STATEMENT OF THE CASE.

A. Nature of the Case, Course of Proceedings, and Disposition Below.

The Defendant McCullah was charged by superseding indictment in the Eastern District of Oklahoma with the following four offenses: narcotics conspiracy in violation of 21 U.S.C. § 846 (count 1); interstate travel for purpose of murder for hire in violation of 18 U.S.C. § 1958(a) (count 14); conspiracy to violate 18 U.S.C. § 1958(a) in violation of 18 U.S.C. § 371 (count 13); and causing a killing in furtherance of a continuing criminal enterprise in violation of 21 U.S.C. § 848(e)(1)(A) (count 16). See Appendix D.

Nine codefendants were charged in the same 29-count superseding indictment which named Mr. McCullah. Three of these codefendants (Arvizu, Carlos and Poncho) were never arrested. Three more codefendants (Thayer, Mendoza and Villa) entered guilty pleas before trial. The remaining three codefendants, Hutching, Molina and Sanchez, were tried jointly with Mr. McCullah. Before trial, the Government gave notice that it would seek the death penalty on count 16 against Mr. McCullah, Hutching and Molina (Appendix C; V.1, Docs. 105, 106).

A two-month jury trial was held in Muskogee, Oklahoma, beginning on January 26, 1993. The jury returned guilty verdicts against Mr. McCullah on all four of the counts in which he was charged (V.4, Doc. 474). Codefendants Molina and Sanchez were also found guilty on all charged counts (V.4, Docs. 473, 475); Hutching was acquitted on two firearm counts, and convicted on all remaining counts against him (V.4, Doc. 472).

Following the guilty verdicts on count 16, the District Court immediately began the sentencing phase of the trial for Hutching, Molina and Mr. McCullah. The penalty cases for the three codefendants were presented and decided in series before the same jury which decided guilt: Hutching first; Molina next; and Mr. McCullah last. In their first two penalty verdicts, the jurors rejected the death penalty for Hutching and Molina (V.5, Docs. 509, 517). The jurors then returned a verdict of death against Mr. McCullah. See Appendix Q at 2. The trial ended on March 23, 1993.

Codefendants Hutching, Molina and Sanchez were sentenced in April of 1993. Each received multiple life sentences. See Appendix Z. Their appeals are pending.

Mr. McCullah was sentenced in November of 1993. The District Court imposed a sentence of death by lethal injection on count 16. See Appendix T at 2. Concurrent life sentences were imposed on counts 1 and 14, and a concurrent 5-year sentence imposed on count 13. See Appendix U at 2. No fines were imposed, but special assessments of $50 were imposed on each of the four counts. This appeal followed (V.6, Doc. 630).

 

B. Facts Relevant to the Issues Presented For Review.

1. The Arvizu Drug Organization: Its Alleged Personnel and Activities.

The charges in this case arose out of the alleged activities of a California-based drug organization managed by Eddie Arvizu (V.45, at 1342-43). Arvizu oversaw the American end of a network which imported cocaine and marijuana from Mexico into southern California, and distributed these drugs in the Los Angeles area and on the United States east coast. From his position at the top of the American end of the organization, Arvizu reported to a shadowy drug chieftain in Mexico known as "El Jefe" (the boss) (V.16, at 204; V.17, at 399; V.18, at 44-51, 151-53).

Trial testimony established that the Arvizu drug organization operated under the cover of several southern California businesses, including a trucking company, a diesel engine maintenance facility, and a van conversion facility. These businesses provided the physical facilities, equipment and logistical support needed to offload and distribute imported drugs; the businesses were also apparently used to launder proceeds from drug sales. Arvizu employed numerous individuals to assist in these activities, in­cluding guards, couriers for drugs and money, laborers, secre­taries, a financial expert, a legal adviser, and others (V.17, at 393, 467; V.18, at 16-23, 26-29, 44-51; V.43, at 868-75, 890-95, 981-82; V.45, at 1257-64).

Although Arvizu maintained several homes in southern California, a ranch which he maintained in a sparsely populated area near Murietta, California, received special attention at trial. That ranch, which was patrolled by armed guards and protected by a sophisti­cated electronic security system, was apparently used by Arvizu as a headquarters for the cash-handling end of his operations (V.16, at 6-7, 101-02, 232-33; V.17, at 330; V.21, at 9-11, 16-17, 79-82; V.45, at 1296-98).

According to Government witnesses, other participants in Arvizu's California drug operations included: the Defendant Ray Molina, Arvizu's cousin and right hand man (V.21, at 48-49, 90; V.51