United States v. Michael Wood


NOT PRECEDENTIAL UNITED STATES COURT OF APPEALS FOR THE THIRD CIRCUIT Nos. 18-3597 and 18-3653 UNITED STATES OF AMERICA v. MICHAEL WOOD, Appellant in No. 18-3597 UNITED STATES OF AMERICA v. MARY WOOD, Appellant in No. 18-3653 On Appeal from the United States District Court for the District of New Jersey (Nos. 1-16-cr-00271-001 & 1-16-cr-00271-002) District Judge: Hon. Robert B. Kugler Submitted pursuant to Third Circuit L.A.R. 34.1(a) November 20, 2019 Before: CHAGARES, MATEY, and FUENTES, Circuit Judges. (Opinion filed: February 6, 2020) OPINION MATEY, Circuit Judge. A jury found Michael and Mary Wood guilty of alien harboring and conspiracy. While they raise a host of arguments seeking to overturn their convictions, we conclude all lack merit. So we will affirm. I. BACKGROUND On June 9, 2016, a grand jury returned an indictment alleging that Michael and Mary Wood used an unlawful alien to provide domestic help, conduct amounting to alien harboring and a conspiracy to commit alien harboring, among other federal crimes.1 As alleged in the indictment, the Woods illegally transported a Kenyan woman—known as “P.I.”—to the United States and forced her to care for their children and home in isolating and controlled conditions. At trial, P.I. testified her ordeal began in July 2005 when the Woods met her in Africa, confiscated her Kenyan passport, and required her to use another individual’s passport to fly to their home in New Jersey. Once there, the Woods forced her  This disposition is not an opinion of the full Court and, pursuant to I.O.P. 5.7, does not constitute binding precedent. 1 Count I charged the Woods with “conspir[ing] and agree[ing] with each other,” in violation of 8 U.S.C. § 1324(a)(1)(A)(v)(I), to: (1) “encourage and induce” P.I. to “come to, enter, and reside in the United States,” in violation of 8 U.S.C. § 1324(a)(1)(A)(iv); (2) “transport and move P.I. within the United States,” in violation of 8 U.S.C. § 1324(a)(1)(A)(ii); and (3) “conceal, harbor, and shield from detection P.I. in any place,” in violation of 8 U.S.C. § 1324(a)(1)(A)(iii). (App. at 35–38.) And Count II charged the Woods with “conceal[ing], harbor[ing], and shield[ing] from detection P.I.” in violation of 8 U.S.C. § 1324(a)(1)(A)(iii). (App. at 38.) The indictment also charged that all crimes were done “for the purpose of private financial gain” in violation of 8 U.S.C. § 1324(a)(1)(B)(i). (App. at 36, 38.) 2 to cook, clean, and care for their four children for nearly a year. P.I. eventually decided to leave and, with help from Mary’s relatives, relocated to Mary’s sister Anne’s home in Pennsylvania. At the close of the Government’s case, the Woods moved for a judgment of acquittal, arguing that the charges were barred by a ten-year statute of limitations. Asserting that the criminal conduct ended when P.I. moved to Anne’s home, they noted that testimony showed only that the move occurred sometime in June 2006,2 insufficient for a jury to find that the charged conduct continued until at least June 9, 2006—that is, ten years before the indictment. ...

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