United States v. Laurence John Layton

Laurence John Layton (Layton) appeals from the final judgment entered following his conviction on charges stemming from the November 1978 killing of Congressman Leo J. Ryan at the Port Kaituma airstrip in the Republic of Guyana. Layton challenges his conviction on numerous grounds, each of which is addressed below.

In a separate appeal, Layton challenges the district court’s denial of his motion under 28 U.S.C. § 2255 to vacate and set aside his conviction. In his motion, Layton argued that he had received ineffective assistance of counsel at trial, in violation of the sixth amendment.

We ordered the consolidation of Layton’s two appeals. We address each in this opinion. For the reasons set forth below, we affirm both the judgment of conviction and the district court’s denial of Layton’s motion under § 2255.

APPEAL NO. 87-1071

I. PERTINENT FACTS

The Peoples Temple was a religious organization composed primarily of American citizens. In 1977, under the leadership of Jim Jones, the Peoples Temple established a settlement of more than 1,000 people in a remote jungle area of the Republic of Guyana. The settlement was known as Jones-town. Layton was a member of the Temple and…