United States v. Jamie Harmon

Defendanb-Appellant Jamie Harmon appeals from her convictions for money laundering. She argues that the prosecutor’s errors before the grand jury constitute structural error, requiring reversal. She also contends that the government’s failure to disclose impeachment evidence about a hostile defense witness mandates a new trial. Because the grand jury errors are not structural, and any impeachment evidence immaterial, we agree with the district court’s well-reasoned analysis and affirm.

I. Factual and Procedural Background

To make a long and convoluted story short: Christian Pantages ran a business that resold stolen computer equipment as legitimate. He was charged in state court with receiving stolen property, and retained Harmon as his criminal defense attorney. Fearing that his bank accounts were frozen, Pantages searched for a way to access the funds derived from his stolen computer equipment scheme. His solution was his attorney, Harmon.

A. The Grand Jury Investigation

Pantages delivered two checks to Harmon totaling $127,550, and she deposited them into her client-trust account. Harmon then wrote multiple checks back to Pan-tages and his wife totaling around…