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] 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.[2] Justice Thomas explained that "[a] reviewing court’s limited determination on sufficiency review ... does not rest on how the jury was instructed."[3] 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.[4]
| 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 |
| Court membership | |
| |
| Case opinion | |
| Majority | Thomas, joined by unanimous |
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- Text of Musacchio v. United States, 577 U.S. ___ (2016) is available from: Justia Oyez (oral argument audio) Supreme Court (slip opinion)