Background
Anthony Zigler, a member of the Almighty Vice Lord Nation gang, stabbed another member, Frank Williams, fifteen times while incarcerated. The government charged Zigler with assault with a dangerous weapon in aid of racketeering, alleging the attack was to maintain his rank within the gang after Williams disrespected the chain of command. Zigler argued the attack was personal and challenged his conviction and sentence on appeal.
The court’s reasoning
The court held that sufficient evidence supported the conviction because Zigler stabbed Williams to maintain his position in the enterprise, satisfying the purpose element of the federal racketeering statute. Regarding sentencing, the court found the district court did not clearly err in applying a cross-reference to assault with intent to murder, as the nature of the stabbing made intent plausible. The court also rejected claims of procedural and substantive unreasonableness regarding the sentence length.
A rational trier of fact could find that Zigler stabbed Williams to maintain his rank within AVLN.
United States v. Zigler, 6th Cir. 2026
What it means going forward
Establishes that gang hierarchy maintenance can satisfy the purpose element for VICAR convictions and affirms deference to district court factual findings on sentencing cross-references.