| Musacchio v. United States | |
|---|---|
 | |
| Argued November 30, 2015 Decided January 25, 2016 | |
| Full case name | Michael Musacchio, Petitioner v. United States |
| Docket no. | 14–1095 |
| Citations | 577 U.S. ___ ( more ) 136 S. Ct. 709; 193 L. Ed. 2d 639 |
| Case history | |
| Prior | On Writ of Certiorari to the United States Court of Appeals for the Fifth Circuit |
| Holding | |
| 1) A sufficiency challenge should be assessed against the elements of the charged crime, not against the elements set forth in an erroneous jury instruction. 2) A defendant cannot successfully raise Section 3282(a)'s statute-of-limitations bar for the first time on appeal. | |
| Court membership | |
| |
| Case opinion | |
| Majority | Thomas, joined by unanimous |
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] [2] 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. [3] Justice Thomas explained that "[a] reviewing court’s limited determination on sufficiency review ... does not rest on how the jury was instructed." [4] 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. [5]