United States v. Lawrence Michael Stanfill El

Defendant Lawrence Michael Stanfill El was charged with assault under a statute that provided for a maximum prison sentence of six months. He requested but was denied a jury trial. Following a bench trial, he was convicted and sentenced to pay restitution in the amount of $3,468.03. He argues that the possibility of being ordered to pay a substantial amount of money in restitution gave him the right to a trial by jury under the Sixth and Seventh Amendments. We disagree and affirm the judgment of the district court.

I. Background

Stanfill El and Kyle Carmín were work-study interns with adjacent workspaces at the Department of Veterans Affairs office in Portland, Oregon. They-had an altercation at work during which Stanfill El punched Carmín several times. Carmín required treatment at a nearby hospital.

Stanfill 1 El was charged with assault within the territorial jurisdiction of the United States by striking, beating, or wounding, under 18 U.S.C. § 113 (a)(4). He pleaded not guilty and demanded a jury trial. His jury demand was denied. Following a bench trial, the magistrate judge found Stanfill El guilty. The magistrate judge ordered him to pay $3,468.03 restitution to…