Musacchio v. United States

Musacchio v. United States, 577 U.S. ___ (2016), was a case in which the Supreme Court of the United States clarified procedures for appellate review when the government does not object to an erroneous jury instruction that adds elements to a criminal offense as well as whether a defendant may raise a statute of limitations defense for the first time on appeal.[1] In a unanimous opinion written by Justice Clarence Thomas, the Court held that when reviewing a claim that the government failed to demonstrate sufficient evidence to substantiate a criminal offense, an appellate court should assess the elements of the alleged crime, rather than the elements that were described in jury instructions.[2] Justice Thomas explained that "[a] reviewing court’s limited determination on sufficiency review ... does not rest on how the jury was instructed."[3] Additionally, with respect to the statute of limitations issue, Justice Thomas held that a statute of limitations defense cannot be raised for the first time on appeal.[4]

Musacchio v. United States
Argued November 30, 2015
Decided January 25, 2016
Full case nameMichael Musacchio, Petitioner v. United States
Docket no.14–1095
Citations577 U.S. ___ (more)
136 S. Ct. 709; 193 L. Ed. 2d 639
Case history
PriorOn Writ of Certiorari to the United States Court of Appeals for the Fifth Circuit
Court membership
Chief Justice
John Roberts
Associate Justices
Antonin Scalia · Anthony Kennedy
Clarence Thomas · Ruth Bader Ginsburg
Stephen Breyer · Samuel Alito
Sonia Sotomayor · Elena Kagan
Case opinion
MajorityThomas, joined by unanimous

See also

References
  1. Musacchio v. United States, No. 14–1095, 577 U.S. ___, slip op. at 1, 6, 11 (2016).
  2. Musacchio, slip op. at 1, 6.
  3. Musacchio, slip op. at 6.
  4. Musacchio, slip op. at 1, 11.
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