Case Explained: USA V. CHAPMAN

Court: United States Court of Appeals for the Ninth Circuit Filed: 2026-08-05 Docket: 2:20-cr-00091- The Ninth Circuit vacated John Chapman’s conviction for kidnapping resulting in death and remanded the case for a new trial due to impermissible jury coercion by the district court. Although the panel affirmed the denial of Chapman’s motion for acquittal, holding that the federal kidnapping statute’s “holding” element can be satisfied through non-physical means such as deception rather than requiring physical force, and affirmed the denial of his motion to suppress a confession finding his Miranda waiver was knowing, intelligent, and voluntary, the conviction could not stand because the jury’s verdict was coerced. The court applied the totality-of-the-circumstances standard to determine jury coercion, identifying four primary factors that rendered the district court’s actions improper. First, the district court gave an Allen charge without disclosing to the parties that it had received two substantive jury notes on the first day of deliberations containing the numerical breakdown of the jurors’ votes; the Ninth Circuit has previously held that giving an Allen charge while knowing the vote count is per se coercive. Second, the district court’s comments during the canvassing of a holdout juror were coercive, as the judge explicitly told the juror to “surrender that opinion” and dismissed evidence the juror relied upon as “irrelevant.” Third, the jury deliberated for only thirty-seven minutes after receiving the Allen charge before returning with a unanimous verdict, a short timeframe that favors a finding of coercion. Finally, other indicia of coerciveness included the court directing comments at a specific holdout juror and the jury being deadlocked when the supplemental instruction was given. The practical consequence is that Chapman’s conviction is vacated and the case is remanded to the District Court for the District of Nevada for a new trial. The panel did not reach the merits of other jury instruction challenges, noting they could be raised in the new trial proceedings. Do It For The Case Law is a news reporting service. Nothing in this episode constitutes legal advice.