United States v. Leonardo Rabanales-Casia

MEMORANDUM

“[Viewing the evidence in the light most favorable to the prosecution,” we conclude that a “rational trier of fact could have found the essential elements of the crime beyond a reasonable doubt.” Jackson v. Virginia, 443 U.S. 307, 319 , 99 S.Ct. 2781 , 61 L.Ed.2d 560 (1979). With respect to Counts I and II, Rabanales-Casia argues that there was insufficient evidence to prove a conspiracy or to prove any element of hostage taking. The elements of hostage taking are that the defendant: (1) seized or detained another person, (2) threatened to kill, injure, or continue detaining that person, and (3) did so “in order to compel a third person or a governmental organization to do or abstain from doing any act as an explicit or implicit condition for the release of the person detained.” 18 U.S.C. § 1203 (a).

The first element is supported by testimony that the aliens were not allowed to leave the house in which they were staying. The second and third, elements are supported by testimony that Rabanales-Casia threatened to leave aliens “hungry and thirsty in a dark room if’ their families did not pay money to the smugglers. That Rabanales-Casia was part of a conspiracy is…