United States v. Ronald Davenport

MEMORANDUM

Defendant-Appellant, Ronald James Davenport (“Davenport”) was convicted by jury trial on four counts of violating 18 U.S.C. § 1521 , retaliating against a Federal judge or Federal law enforcement officer by false claim or slander of title. He appeals his conviction. We have jurisdiction pursuant to 18 U.S.C. § 3742 and 28 U.S.C. § 1291 , and we affirm the district court.

1. Davenport filed documents entitled “Notice of Claim of Maritime Lien” on properties of government officials. In each document, the “vessels” are identified by the officials’ names, i.e. the U.S. MW James McDevitt, the U.S. M/V James Larson, etc. The documents also contain a detailed description of the officials’ real and personal property that is attached to the claim along with “any other thing of value as needed to satisfy this claim.” Davenport argues that these documents cannot be the basis of his conviction because they are notices of liens, not actual liens, and that they are invalid because they could not attach to a maritime vessel.

The district court properly applied the plain meaning of the terms “lien” and “encumbrance” in concluding that Davenport’s “Notice of Claims of Maritime Liens”…