Case Explained: United States of America v. Shaquiel Anthony Mendez

Court: United States Court of Appeals for the Eighth Circuit

Filed: 2026-07-15

The Eighth Circuit affirmed the conviction of Shaquiel Mendez for conspiracy to tamper with a witness in violation of 18 U.S.C. § 1512(k), specifically finding sufficient evidence to support the charge under 18 U.S.C. § 1512(a)(2)(C). The court applied the standard established in *Fowler v. United States*, requiring the government to prove that it was “reasonably likely” under the circumstances that the witness would have communicated with a federal law enforcement officer regarding a federal offense if the tampering had not occurred. This standard does not require proof that such communication would definitely occur, but rather that the likelihood was more than remote, outlandish, or hypothetical. The court held that this standard was met because the victim, Joshua Brooks, had already proffered to federal agents regarding a murder investigation prior to the assault and had not withdrawn from cooperation with federal authorities at the time of the incident. The record indicated that Brooks remained reasonably likely to communicate further with federal officers about the possible commission of a federal offense, satisfying the required “federal nexus.” Consequently, Mendez’s conviction stands, and his 240-month sentence remains in effect.

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