Background
The case stems from the activities of the Uniones Locos Salvatrucha clique of the Mara Salvatrucha gang. The defendant, Elmer de Jesus Alas Candray, served as the group’s second-in-command. He was the sole defendant to stand trial after other co-defendants entered plea agreements. A jury convicted him on fourteen counts, including racketeering conspiracy and multiple counts of murder in aid of racketeering, related to six murders and one attempted murder between 2018 and 2022. The district court sentenced him to six concurrent life sentences.
The court’s reasoning
The court reviewed the sufficiency of the evidence de novo, viewing the facts in the light most favorable to the government. It found that cooperating witnesses provided ample testimony placing the defendant at the scenes of the crimes, planning the murders, and participating in the killings. The court noted that the defendant’s argument regarding his physical absence during certain murders was irrelevant to conspiracy liability. Regarding the Eighth Amendment challenge, the court relied on its precedent in United States versus Contreras, which established a bright line at age eighteen. Since the defendant was twenty-one at the time of the offenses, the court held that mandatory life sentences do not constitute cruel and unusual punishment.
We must uphold the jury’s verdict if any rational trier of fact could have found the essential elements of the crime beyond a reasonable doubt.
United States v. Huskey, 90 F.4th 651, 662 (4th Cir. 2024)
What it means going forward
The decision reinforces the Fourth Circuit’s strict approach to sufficiency challenges in gang-related racketeering cases and confirms that mandatory life sentences for adult defendants convicted of murder in aid of racketeering are constitutional.