Background
John Matthew Chapman was convicted in the District of Nevada of kidnapping resulting in death under 18 U.S.C. § 1201(a)(1). The government alleged that Chapman deceived Jamie Feden into traveling with him from Pennsylvania to Las Vegas, where he bound her in a remote desert and taped her mouth and nose, causing her death.
At trial, Chapman argued that there was insufficient proof he “held” Feden within the meaning of the federal kidnapping statute and challenged the admission of his confession. During deliberations, the district court received but did not disclose notes revealing that the jury was divided ten to two and appeared deadlocked. The court later questioned an identified holdout juror about the juror’s reliance on defense expert testimony. The jury returned a unanimous guilty verdict 37 minutes later.
The Court’s Holding
The Ninth Circuit vacated the conviction and remanded for a new trial because the district court improperly coerced the verdict. Giving an Allen-type supplemental instruction while aware of the jury’s numerical division was impermissibly coercive. The court’s comments directing the holdout juror to “surrender” an opinion and minimizing evidence the juror was considering, combined with the swift verdict after two days of deadlock, independently reinforced that conclusion.
The court nevertheless affirmed the denial of Chapman’s motion for acquittal. For the first time in the circuit, it held that the kidnapping statute’s “holding” element may be established through nonphysical restraint, including deception, in an inveiglement case. The evidence permitted a rational jury to find that Chapman deceived and held Feden. The court also upheld the denial of suppression, concluding that Chapman knowingly and intelligently waived his Miranda rights and that his confession was voluntary.
Key Takeaways
- A defendant may “hold” a kidnapping victim through deception or other nonphysical restraint.
- An Allen-type charge given after the court learns the jury’s numerical split can require reversal for jury coercion.
- Questioning an identified holdout juror in a way that disparages the juror’s view of the evidence can be coercive.
Why It Matters
The decision establishes Ninth Circuit precedent that federal kidnapping by inveiglement does not require physical force to satisfy the statute’s holding element. It also underscores the strict limits on a trial judge’s intervention with a deadlocked jury, especially when the judge knows the numerical division or targets a juror’s evidentiary reasoning.