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Criminal – Witness-Tampering Instruction Was ‘Harmless Error’ (access required)

U.S. v. Smith Although a jury instruction at defendant’s trial for witness tampering misstated the federal nexus required for the offense, under a 2011 U.S. Supreme Court decision that came down after defendant’s conviction became final, the jury instruction was “harmless error” and the 4th Circuit rejects defendant’s 28 U.S.C. § 2255 motion for post-conviction relief.

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