In United States v. Maldonado-Passage, — F.4th —, 2022 U.S. App. LEXIS 35541 (Dec. 23, 2022), the U.S. Court of Appeals for the Tenth Circuit upheld a 252-month sentence for Joseph “Tiger King” Maldonado-Passage based primarily on his conviction on two murder-for-hire schemes. The circuit court rejected two procedural and two substantive challenges to his new sentence imposed after a prior appeal and remand. In the process, the court ruled that his two schemes to murder one person constituted two separate offenses under 18 U.S.C. §1958(a), a federal statute that criminalizes the use of interstate travel or the facilities of interstate commerce in a murder-for-hire scheme.
Factual Background
Maldonado-Passage’s two murder-for-hire counts arose out of a dispute with Carol Baskin, an activist who felt he was mistreating animals in his Oklahoma zoo. Id. at *3. Their rivalry was featured in the 2020 Netflix documentary Tiger King: Murder, Mayhem, and Madness. Id. With respect to his first count, in November 2017, he solicited a zoo employee, Alan Glover, to kill Baskin; provided him with a phone preloaded with pictures of her; and organized and paid him $3,000 for his interstate travel to Florida to murder her. Id. at *4. Glover traveled from Oklahoma to Florida but didn’t try to kill her. Id.
This content has been archived. It is available through our partners, LexisNexis® and Bloomberg Law.
To view this content, please continue to their sites.
Not a Lexis Subscriber?
Subscribe Now
Not a Bloomberg Law Subscriber?
Subscribe Now
LexisNexis® and Bloomberg Law are third party online distributors of the broad collection of current and archived versions of ALM's legal news publications. LexisNexis® and Bloomberg Law customers are able to access and use ALM's content, including content from the National Law Journal, The American Lawyer, Legaltech News, The New York Law Journal, and Corporate Counsel, as well as other sources of legal information.
For questions call 1-877-256-2472 or contact us at [email protected]