United States v. William Boylston

Summary

The Sixth Circuit affirmed the convictions and sentences of seven members and associates of the Clarksville, Tennessee chapter of the Mongols Motorcycle Club, who were convicted after a joint 38-day trial on RICO conspiracy, drug-trafficking, money-laundering, kidnapping, VICAR murder, and firearm counts arising from the chapter's 2015 formation and its campaign of drug distribution and violence. The court held the evidence sufficient to establish the Clarksville Mongols as an association-in-fact enterprise from March 2015 and each appellant's knowing participation, and rejected challenges to the semi-anonymous jury, the government's gang expert, other trial evidence, the denials of severance and mistrial, and the jury instructions. It further held that a three-week COVID-related delay before cross-examination of a key witness did not violate the Confrontation Clause, and that future-tense enterprise instructions neither constructively amended the indictment nor produced a prejudicial variance.