United States v. Matthew Evans Dowd

A jury convicted Matthew Evans Dowd of violating the federal interstate domestic violence law. He argues that the jury did not have sufficient evidence that he forced or coerced his companion, Danna Johnson, to cross state lines, as the statute requires, because she had reasonable opportunities to escape.

Dowd also challenges the district court’s decision to impose a sentence for the domestic violence crime that is consecutive to his sentence for previous drug-related crimes. He further argues that the district court improperly enhanced his sentence as a sexual crime in violation of Apprendi v. New Jersey, 530 U.S. 466 , 120 S.Ct. 2348 , 147 L.Ed.2d 435 (2000).

We affirm Dowd’s conviction. The evidence demonstrated that Dowd subjected Johnson to numerous instances of physical and psychological abuse as they traveled through Montana, Colorado and Utah. Viewed from the perspective of a reasonable woman in Johnson’s circumstances, the jury could readily have found that Dowd, through a combination of actual force and dire threats, compelled Johnson to stay with him and made her fearful of attempting to flee.

We further affirm Dowd’s sentence because the district court properly…