United States v. Jose Ramon Garcia, United States of America v. Edward Michael Powers

Edward Michael Powers and Jose Ramon Garcia are former correctional officers at Pelican Bay State Prison who were convicted of conspiring with other correctional officers to organize stabbings, assaults, and intimidation of selected inmates by other inmates from July 1992 through August 1994. A jury found them guilty of violating 18 U.S.C. § 241 , in that they “conspir[ed] to injure, oppress, threaten, or intimidate ... person[s] ... in the free exercise or enjoyment of ... right[s] or privilege[s] secured to[them] by the Constitution or laws of the United States.” They were sentenced to 84 and 76 months in prison, respectively. The defendants moved the district court to release them on bail pending their appeal to this court. The district court denied their motion, holding that they had not shown “exceptional reasons” justifying bail, as required under 18 U.S.C. § 3145 (c). In this opinion we address for the first time the meaning of the term “exceptional reasons.” We vacate the district court’s ruling and remand for further proceedings in light of this opinion.

In general, persons convicted of federal crimes are not eligible for release pending appeal unless a court…