Criminal Law, Pages 496–500

United States v. Valle

Federal District Court of the Southern District of New York, 2014
Advisory: This brief may contain disturbing or offensive content.
I've tried to write it professionally, but be aware that you might not want to read it if you don't have to.
This was generated automatically because of the following tags: rape

Facts:

Defendant was an active member of a sexual fetish website where users traded pictures of women and talked about their supposed plans to commit acts of sexual violence against the women. Despite defendant discussing about how he was going to kidnap, torture, rape, murder, and cannibalize women, no physical steps were ever taken in furtherance of any of these acts. Defendant's profile page even said that it was all just fantasy.

Procedural History:

Defendant was convicted of conspiracy to commit kidnapping.

Issue:

Did defendant have the specific intent to actually kidnap these women?

Reasoning:

No reasonable juror could have found that defendant actually intended to kidnap a woman on the dates he gave. He once agreed to kidnap three women in one day, and one of them was not even on the same continent as he was. After the dates for the "planned" kidnappings pass, the discussions are dropped without follow-up or further comment.

Defendant lied about many aspects of himself in many aspects as well. He said he had torture equipment in a soundproof basement, a human-size oven, and the addresses of the purported targets where he was conducting surveillance. He made up information about the women as well and never gave their real last names or locations.

Given this context, there is no evidence that defendant actually intended to commit the acts, just that he is very misogynistic and depraved.

Holding:

No, defendant did not have the specific intent to kidnap these women. Conspiracy charge dismissed, and a new trial granted therefor.

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