U.S. v. Edwards

In prosecution on charges of witness tampering, Dist. Ct. erred in giving instruction that failed to include requirement that defendant had “corruptly” attempted to persuade another person to hinder, delay or prevent communication of information to federal criminal investigators. Instant instruction failed to convey requisite consciousness of wrongdoing and improperly allowed jury to convict defendant based on innocent acts of obstruction. As such, defendant was entitled to new trial on witness tampering charges. However, Dist. Ct. did not err in denying defendant’s motion to dismiss witness tampering charges on grounds that term “corruptly” was too vague when applied to factual setting in instant case in which charges alleged that defendant had tried to persuade another person to lie when said person had legal duty to tell truth. Moreover, record contained sufficient evidence to support said charges, where properly instructed jury could have believed that defendant acted dishonestly by pressuring another individual to lie to investigators about said individual's alleged fraudulent marriage to alien.