United States v. Chapman

── United States v. Chapman ── Court: Court of Appeals for the Ninth Circuit Date: May 08, 2026 Category: General FOR PUBLICATION UNITED STATES COURT OF APPEALS FOR THE NINTH CIRCUIT UNITED STATES OF AMERICA, No. 24-4939 D.C. No. Plaintiff - Appellee, 2:20-cr-00091- JCM-DJA-1 v. JOHN MATTHEW CHAPMAN, OPINION Defendant - Appellant. Appeal from the United States District Court for the District of Nevada James C. Mahan, District Judge, Presiding Argued and Submitted January 7, 2026 San Francisco, California Filed May 8, 2026 Before: Ronald M. Gould, Jacqueline H. Nguyen, and Mark J. Bennett, Circuit Judges. Opinion by Judge Gould 2 USA V. CHAPMAN SUMMARY* Criminal Law The panel vacated John Chapman’s conviction for kidnapping resulting in death in violation of 18 U.S.C. § 1201(a)(1) and remanded for a new trial. The federal kidnapping statute has three primary elements, and four when death is alleged to have resulted from the kidnapping: (1) that the defendant “seizes, confines, inveigles, decoys, kidnaps, abducts, or carries away” the victim; (2) that the defendant “holds” the victim; (3) that the victim is “willfully transported in interstate or foreign commerce” or that the defendant uses “any means, facility, or instrumentality of interstate or foreign commerce” in committing the kidnapping; and (4) that the kidnapping resulted in death. Affirming the district court’s denial of Chapman’s post- verdict motion for acquittal, the panel held (1) the “holding” element of the federal kidnapping statute does not require a use of physical force, and an individual may be “held” against their will through a means of deception in an inveiglement case; and (2) there was sufficient evidence for a jury to conclude that Chapman “held” the victim by non- physical forms of “holding,” including deception. The panel vacated the conviction and remanded for a new trial, however, because, as the parties conceded, the district court improperly coerced the jury’s verdict. First, * This summary constitutes no part of the opinion of the court. It has been prepared by court staff for the convenience of the reader.  USA V. CHAPMAN 3 the district court gave an Allen charge without disclosing to the parties that it had received on the first day of deliberations two substantive jury notes that contained the numerical breakdown of the jurors’ votes. This was impermissible jury coercion. Second, the district court’s comments when canvassing a juror were coercive under the totality of the circumstances. Third, the deliberation of only thirty minutes after receiving the Allen charge favors a finding of coercion. There were, finally, other indicia of coerciveness. Affirming the district court’s denial of his motion to suppress his confession, the panel held that Chapman knowingly and intelligently waived his Miranda rights and that his confession was voluntary. COUNSEL Andrew C. Noll (argued), Trial Attorney, Appellate Section; Matthew R. Galeotti, Acting Assistant Attorney General; Criminal Division, United States Department of Justice, Washington, D.C.; Penelope J. Brady, Peter H. Walkingshaw, Megan Rachow, Adam M. Flake, and Steven J. Rose, Assistant United States Attorneys; Sigal Chattah, United States Attorney; Office of the United States Attorney, United States Department of Justice, Las Vegas, Nevada; for Plaintiff-Appellee. Jeremy C. Baron (argued), Ellesse Henderson, and Nicholas Wolfram, Assistant Federal Public Defenders; Rene L. Valladares, Federal Public Defender; Office of the Federal Public Defender, Las Vegas, Nevada; for Defendant- Appellant. 4