US v. Coleman
Split Score
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Case Summary
Disposition
Affirmed
The First Circuit affirmed Louis D. Coleman III’s conviction and life sentence for kidnapping resulting in death under 18 U.S.C. § 1201(a)(1). Rejecting numerous trial-level challenges, the court upheld the indictment’s sufficiency, the admission and exclusion of key evidence, jury instructions, and the denial of a mistrial; it also found the evidence sufficient to prove Coleman lured, confined, sexually assaulted, and killed Jassy Correia and transported her across state lines. Significantly, the court declined to adopt the "incidental-kidnapping" limitation used by several other circuits, thereby creating an explicit split on whether a kidnapping hold must exceed the time needed to commit an accompanying crime.
Circuit Split Identified
Legal Issue
Whether the federal kidnapping statute, 18 U.S.C. § 1201(a)(1), requires that a victim be held for a period appreciably longer than the time necessary to commit an accompanying offense (the 'incidental-kidnapping' or Berry test).
Circuit Positions
No incidental-kidnapping exception; a hold is appreciable even if concurrent with another crime—plain statutory text controls.
Apply Berry incidental-kidnapping test—hold must be appreciably longer than time needed to commit the underlying offense.
Conflict Summary
The Third, Eleventh, Ninth, Second and Tenth Circuits apply the Berry line of cases, holding that a kidnapping detention must substantially exceed the duration inherent in another offense (e.g., assault, robbery) to satisfy the 'appreciable period' requirement. The First Circuit expressly rejected that approach, reading the statute’s text to require only an involuntary hold of appreciable length, even if it coincides with the time needed to commit the related crime.