Sign In
Events
Newsletters
Search

Close

Close Search

Cancel

SEARCH
MY LAW.COMNEW

United States of America v. America Yegile Haileselassie

X

Thank you for sharing!

Your article was successfully shared with the contacts you provided.
Submitted: December 14, 2011

Before LOKEN, BRIGHT, and SHEPHERD, Circuit Judges.

America Haileselassie sent the Bettendorf, Iowa Police Department an envelope containing white powder and a letter reading: “Detective Bryan Payton; You are a Dead MeaT; I will kill you all You son of a Bitch!; Enjoy the Anthrax Spores!” The Iowa State Hygienic Lab (the “State Lab”) determined that the powder was a blend of baby powder and carpet cleaner, and investigators traced the letter to Haileselassie. He pleaded guilty to mailing a threatening communication in violation of 18 U.S.C. § 876(c) and was sentenced to 21 months in prison. He appeals the district court’s order that he pay restitution in the amount of $1,401.44 to the State Lab. We agree with the district court that 18 U.S.C. § 876(c) is a crime of violence within the meaning of the Mandatory Victims Restitution Act (“MVRA”), 18 U.S.C. § 3663A, and that the State Lab can be a victim under the MVRA. However, as the government failed to prove the amount of actual loss, we reverse the restitution order.

Trending Stories

 
Reprints & Licensing
Mentioned in a Law.com story?

License our industry-leading legal content to extend your thought leadership and build your brand.

LEARN MORE

More From ALM

Premium Subscription
With this subscription you will receive unlimited access to high quality, online, on-demand premium content from well-respected faculty in the legal industry. This is perfect for attorneys licensed in multiple jurisdictions or for attorneys that have fulfilled their CLE requirement but need to access resourceful information for their practice areas.
View Now
Team Accounts
Our Team Account subscription service is for legal teams of four or more attorneys. Each attorney is granted unlimited access to high quality, on-demand premium content from well-respected faculty in the legal industry along with administrative access to easily manage CLE for the entire team.
View Now
Bundle Subscriptions
Gain access to some of the most knowledgeable and experienced attorneys with our 2 bundle options! Our Compliance bundles are curated by CLE Counselors and include current legal topics and challenges within the industry. Our second option allows you to build your bundle and strategically select the content that pertains to your needs. Both options are priced the same.
View Now
Go to CLE Center
General Counsel Conference Midwest: SuperConference 2025
April 08, 2025 - April 09, 2025
Chicago, IL

Join General Counsel and Senior Legal Leaders at the Premier Forum Designed For and by General Counsel from Fortune 1000 Companies


Learn More
GlobeSt. Healthcare Real Estate 2024
December 02, 2024 - December 03, 2024
Scottsdale, AZ

Join the industry's top owners, investors, developers, brokers and financiers for the real estate healthcare event of the year!


Learn More
ThinkAdvisor LUMINARIES Awards 2024
December 11, 2024
Las Vegas, NV

This event shines a spotlight on how individuals and firms are changing the investment advisory industry where it matters most.


Learn More
Go to Events Go to Webcasts
ATTORNEY - REMOTE - NEW YORK

Experienced Insurance Defense Attorney.No in office requirement.Send resume to:


Apply Now ›
School Law Associate

We are seeking two attorneys with a minimum of two to three years of experience to join our prominent and thriving education law practice in...


Apply Now ›
Real Estate Litigation Associate - New York, NY

Description: Fox Rothschild has an opening in the New York office for a Real Estate Litigation Associate with three to six years of commerci...


Apply Now ›
Go to Lawjobs