United States v. Latasha Lorraine Arnt, A/K/A Latasha Lorraine Simpson and Latasha L. Cummings

A jury convicted LaTasha Lorraine Arnt of committing voluntary manslaughter while accompanying the Armed Forces of the United States in Turkey, in violation of 18 U.S.C. §§ 1112 (a), 3261(a). The court sentenced her to eight years in prison and ordered her to pay restitution to the victim’s family.

On appeal, Arnt raises several challenges to her conviction and sentence. She asserts that the indictment failed to allege an essential element and challenges several aspects of her conviction, including the sufficiency of the evidence and the court’s refusal to give an involuntary manslaughter instruction. Finally, she argues that her sentence is unreasonable and contends that the restitution order is illegal because it defines “victim” too broadly.

We reject her challenge to the indictment, which was sufficient to identify the jurisdictional basis of the prosecution. Similarly, we reject her challenge to the sufficiency of the evidence, which provided an adequate basis to establish, beyond a reasonable doubt, that Arnt was accompanying the Armed Forces outside the United States at the time of her offense. We agree with Arnt, however, that the district court committed reversible…