USCA Case #23-3143 Document #2016974 Filed: 09/14/2023 Page 1 of 16
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`IN THE
`UNITED STATES COURT OF APPEALS
`FOR THE DISTRICT OF COLUMBIA CIRCUIT
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`Case No. 23-3143
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`UNITED STATES OF AMERICA,
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`Appellee,
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`v.
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`LAUREN HANDY,
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`Appellant.
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`DEFENDANT-APPELLANT LAUREN HANDY’S
`REPLY IN SUPPORT OF MOTION FOR
`RELEASE PENDING SENTENCING
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`INTRODUCTION
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`
`
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`The Government’s Opposition Brief would re-write the FACE Act
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`into a statute that prohibits only non-reckless force by ignoring what
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`reckless force actually means.
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`
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`“A person acts recklessly, in the most common formulation, when
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`he ‘consciously disregard[s] a substantial [and unjustifiable] risk that the
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`conduct will cause harm to another.’” Counterman v. Colorado, 600 U.S.
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`__, 143 S. Ct. 2106, 2117 (2023) (emphasis added) (quoting Voisine v.
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`United States, 579 U.S. 686, 691 (2016)). This is distinct from force that
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`“knowingly or intentionally” seeks to cause “harm.” Voisine, 579 U.S. at
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`691 (emphasis added). But reckless force is still “morally culpable
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`1
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`IN THE
`UNITED STATES COURT OF APPEALS
`FOR THE DISTRICT OF COLUMBIA CIRCUIT
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`Case No. 23-3143
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`UNITED STATES OF AMERICA,
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`Appellee,
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`v.
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`LAUREN HANDY,
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`Appellant.
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`DEFENDANT-APPELLANT LAUREN HANDY’S
`REPLY IN SUPPORT OF MOTION FOR
`RELEASE PENDING SENTENCING
`
`INTRODUCTION
`
`
`
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`The Government’s Opposition Brief would re-write the FACE Act
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`into a statute that prohibits only non-reckless force by ignoring what
`
`reckless force actually means.
`
`
`
`“A person acts recklessly, in the most common formulation, when
`
`he ‘consciously disregard[s] a substantial [and unjustifiable] risk that the
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`conduct will cause harm to another.’” Counterman v. Colorado, 600 U.S.
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`__, 143 S. Ct. 2106, 2117 (2023) (emphasis added) (quoting Voisine v.
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`United States, 579 U.S. 686, 691 (2016)). This is distinct from force that
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`“knowingly or intentionally” seeks to cause “harm.” Voisine, 579 U.S. at
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`691 (emphasis added). But reckless force is still “morally culpable
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`1
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`USCA Case #23-3143 Document #2016974 Filed: 09/14/2023 Page 2 of 16
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`conduct, involving a deliberate decision to endanger another” that gov-
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`ernment has an interest in proscribing. Counterman, 143 S. Ct. at 2117
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`(internal quotes omitted).
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`
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`The Government here ignores the Supreme Court teaching that
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`such reckless force is not sufficiently “against another” (i.e., “directed at”
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`or “targeting” another) to be a crime of violence. See Borden v. United
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`States, 141 S. Ct. 1817, 1830 (2021) (“[C]rimes [of violence] are best un-
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`derstood to involve not only a substantial degree of force, but also . . . a
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`deliberate choice of wreaking harm on another, rather than mere indiffer-
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`ence to risk [of harm]”) (emphasis added). The parties agree that sub-
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`stantial force is required—force sufficient to cause injury—to constitute
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`FACE Act “force.” But the intent and object of the force prohibited by
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`FACE includes force intended to injure, intimidate, or interfere with an-
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`other, 18 U.S.C. § 248(a)(1)—i.e., force even when not intended to harm
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`another.
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`
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`Indeed, just last term the Supreme Court held that because of First
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`Amendment speech protections, government may punish “true threats”
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`only if a defendant at least “act[ed] recklessly.” Counterman, 143 S. Ct.
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`at 2117 (alteration added). Justice Barrett observed in dissent that this
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`2
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`USCA Case #23-3143 Document #2016974 Filed: 09/14/2023 Page 3 of 16
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`means government enforcement of FACE’s prohibition on “threat[s] of
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`force” must now at least prove a defendant acted recklessly. Id. at 2140-
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`41 (Barrett, J., dissenting) (alteration in original). A
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`misdemeanor
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`FACE conviction categorically includes reckless conduct and, therefore,
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`is not a crime of violence. None of the Government’s remaining conten-
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`tions, discussed below, shows otherwise. And the Government does not
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`dispute that Ms. Handy meets the conditions to be released if she has not
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`committed a crime of violence. Accordingly, this Court should free Ms.
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`Handy pending sentencing.
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`ARGUMENT
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`A. The Government Misapplies the Modified Categorical
`Approach.
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`The Government argues that whenever a statute is divisible (i.e.
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`has multiple elements), courts “must” apply the modified categorical ap-
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`proach and look behind the statute to determine the crime of conviction.
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`(Br. 9-11.) Tellingly, it fails to quote even one case in support of this as-
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`sertion and ignores caselaw holding otherwise.
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`As Handy has explained (Mot. 11), the Supreme Court has held that
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`courts may look to “extra-statutory documents only when a statute de-
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`fines [the crime at issue] . . . alternatively, with one statutory phrase
`3
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`USCA Case #23-3143 Document #2016974 Filed: 09/14/2023 Page 4 of 16
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`corresponding to the generic crime [of violence definition] and another
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`not.” Descamps v. United States, 570 U.S. 254, 265 (2013) (emphasis
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`added). But “the inquiry is over” if the statutory elements “do[] not cor-
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`respond to the relevant generic offense.” Id.; see also Mathis v. United
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`States, 579 U.S. 500, 505 (2016) (authorizing modified categorical ap-
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`proach where one of statute’s elements “would match” the generic of-
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`fense, and another would not).
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`The Government ignores this rule and argues that because FACE
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`has multiple elements, this Court should automatically look to extra-
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`statutory documents like the charging documents and jury instructions.
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`However, the Government fails to first consider whether the different el-
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`ements actually match the meaning of “crime of violence” in 18 U.S.C. §
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`3156(a)(4)(A). And, as Handy has explained (Mot. 12-21), because a mis-
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`demeanor FACE conviction under 18 U.S.C. § 248(b)(1) does not match
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`the meaning of “crime of violence,” “it precludes [] an inquiry into how
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`any particular defendant may commit the crime.” United States v. Taylor,
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`142 S. Ct. 2015, 2020 (2022) (emphasis added).
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`Accordingly, both the Government and the District Court have
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`wrongly assumed that the modified categorical approach applies simply
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`4
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`USCA Case #23-3143 Document #2016974 Filed: 09/14/2023 Page 5 of 16
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`because a FACE misdemeanor under § 248(b)(1) contains a higher pun-
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`ishment (up to one year) than a misdemeanor under § 248(b)(2) (up to six
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`months), because they fail to actually determine whether the former “al-
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`ways requires the government to prove . . . the use, attempted use, or
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`threatened use of force” against another as a categorical matter, under
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`the parameters explained by the Supreme Court. Taylor, 142 S. Ct. at
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`2020. As the High Court made clear, it is not enough that the offense at
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`issue may involve a use of “force.”
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`B. The Government Misapprehends and Conflates FACE’s
`Intent Requirements.
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`The Government accuses Handy of misunderstanding and misread-
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`ing the FACE Act (Br. at 16), but, as previewed above, it is the Govern-
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`ment that misconstrues the Act.
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`The Government argues that FACE prohibits only “intentional . . .
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`conduct” because it requires that one specifically intend to “injure, intim-
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`idate, or interfere with” another. 18 U.S.C. § 248(a)(1) (Br. 19; see also id.
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`(“courts . . . have held that the statute requires intentional action and a
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`specific purpose by the defendant”).) But the Government is conflating
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`three different aspects of the offense.
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`5
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`USCA Case #23-3143 Document #2016974 Filed: 09/14/2023 Page 6 of 16
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`A FACE Act violation under § 248(a)(1) requires three things: First,
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`one must act “by force or threat of force or by physical obstruction.” §
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`248(a)(1). It’s clear that “force” “must be volitional.” Voisine, 579 U.S. at
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`693; see also United States v. Castleman, 572 U.S. 157, 170 (2014) (“use”
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`of “force” inherently means a “knowing or intentional application of
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`force”). But a use of “force,” by itself, “does not demand that the person
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`applying the force have the practical certainty that it will cause harm;”
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`in other words, it is “indifferent as to whether the actor has the mental
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`state of intention, knowledge, or recklessness with respect to the harmful
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`consequences of his volitional conduct.” Voisine, 579 U.S. at 693 (empha-
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`sis added).
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`Second, one must “intentionally injure[], intimidate[] or interfere[]
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`with” another (or attempt to do so). § 248(a)(1) (emphasis added). This is
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`the Act’s “specific intent” requirement, i.e., that one “not merely intend[]
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`the physical act but act[] with the specific intent to injure, intimidate, or
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`interfere.” New York v. Griepp, 991 F.3d 81, 136 n.2 (2d Cir. 2021) (Liv-
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`ingston, C.J., concurring in part), reh’g granted and opinion vacated sub
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`nom. People v. Griepp, 997 F.3d 1258 (2d Cir. 2021), and on reh’g sub.
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`nom. New York by James v. Griepp, 11 F.4th (2d Cir. 2021); accord United
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`6
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`USCA Case #23-3143 Document #2016974 Filed: 09/14/2023 Page 7 of 16
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`States v. Mahoney, 247 F.3d 279, 283-84 (D.C. Cir. 2001) (defendant must
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`have “requisite specific intent” to violate FACE). But this requirement
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`does not mean one must use force with the intent to injure (or intimidate)
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`another, since intent to “interfere with” another is sufficient. 18 U.S.C. §
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`248(a)(1). And FACE defines “interfere with” to mean “restrict[ing] a per-
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`son’s freedom of movement,” i.e., without requiring bodily harm. 18
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`U.S.C. § 248(e)(3).
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`Finally, one must act “because that person is or has been, or in order
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`to intimidate such person . . . from, obtaining or providing reproductive
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`health services.” § 248(a)(1) (emphasis added). This is “[t]he statue’s mo-
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`tive requirement,” Terry v. Reno, 101 F.3d 1412, 1420 (D.C. Cir. 1996),
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`and it is an entirely “separate . . . requirement” from the specific-intent
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`component. Sharpe v. Conole, 386 F.3d 482, 484 (2d Cir. 2004).
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`The Government must establish all three aspects of the offense to
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`convict under § 248(a)(1). But contrary to the Government’s arguments
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`(predicated on a conflation of the Act’s three separate components), noth-
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`ing in the Act requires that an act of “force” involve a “deliberate choice”
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`to inflict “consequent harm,” Borden, 141 S. Ct. at 1823 (defining inten-
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`tional force), because it expressly prohibits even volitional “force”—
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`7
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`USCA Case #23-3143 Document #2016974 Filed: 09/14/2023 Page 8 of 16
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`motivated by stopping reproductive health services—that does not intend
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`harm, but merely to interfere with abortion access.
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`C. Courts Recognize that FACE and Other Civil Rights
`Laws Prohibit Reckless Conduct.
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`The Government accuses Handy of failing to cite any cases support-
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`ing this position. (Br. 20.) But in addition to Counterman cited above, at
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`least one district court found that defendants violated FACE by acting
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`“in reckless disregard of plaintiffs’ rights.” Planned Parenthood of Colum-
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`bia/Willamette, Inc. v. Am. Coal. of Life Activists, 41 F. Supp. 2d 1130,
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`1149 (D. Or. 1999), vacated, 244 F.3d 1007 (9th Cir. 2001), on reh’g en
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`banc, 290 F.3d 1058 (9th Cir. 2002), as amended (July 10, 2002), and aff’d
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`in part, rev’d in part (290 F.3d 1058) (9th Cir. 2002), as amended (July
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`10, 2002).1
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`Another district court found a FACE “force” violation where the de-
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`fendant “knock[ed] over” a clinic escort “in an attempt to counsel a pa-
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`tient,” accusing the escort of getting in his way. United States v. Scott,
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`958 F. Supp. 761, 775 (D. Conn. 1997).2
`
`
`1 The Government rightly does not argue that “threat of force” is a separate
`element from “force,” as both are punished identically under § 248(b)(1).
`2 Ms. Handy does not concede that making contact with an escort outside a
`clinic involves the requisite motive to obstruct reproductive services “in a . . .
`
`
`
`
`8
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`USCA Case #23-3143 Document #2016974 Filed: 09/14/2023 Page 9 of 16
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`Yet another district court has recognized that federal law authoriz-
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`ing civil actions for conspiracies “to deter, by force, intimidation, or
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`threat, any party or witness” in court from attending or testifying, can be
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`violated by “reckless indifference” and “serious disregard” for plaintiffs’
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`rights, sufficient to authorize punitive damages. Odum v. Rayonier, Inc.,
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`No. CIV.A CV204-190, 2005 WL 3440817, at *5 (S.D. Ga. Dec. 14, 2005)
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`(citing 42 U.S.C. § 1985(2)), aff’d, 316 F. App’x 855 (11th Cir. 2008).
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`Accordingly, Ms. Handy’s position here is hardly novel.
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`D. The Government Fails to Undermine Ms. Handy’s Hy-
`potheticals.
`
`The Government dismisses Ms. Handy’s running-into-an-open-
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`
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`doorway hypothetical as necessarily targeting “another person.” (Br. 20.)
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`But it fails to acknowledge that one could run forcefully into a clinic with
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`an intent to interfere with abortion via obstruction, and then be charged
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`with both force and physical obstruction (as Handy was here), especially
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`if they knock someone down (e.g., a clinic nurse) on their way in (without
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`any evidence that knocking someone down was their conscious object).
`
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`facility,” 18 U.S.C. § 248(a)(1), (e), but this case is an illustrative application of
`the “force” clause.
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`
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`9
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`USCA Case #23-3143 Document #2016974 Filed: 09/14/2023 Page 10 of 16
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`The Government’s response to the sledge-hammer-against-one’s-
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`own-car hypothetical also fails (Br. 21), since it merely asserts that would
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`be only a physical obstruction, without any assurance that a different
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`prosecutor would not charge it as both obstruction and force—especially
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`since the force charge would bump the offense up to the “more serious
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`misdemeanor” under § 248(b)(1).
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`Similarly, FACE would also plainly apply to forcefully pushing open
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`an unlocked abortion clinic door, without knowing for sure whether a
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`clinic worker was behind it inside. That would be a use of force sufficient
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`to cause pain to another, see Johnson v. United States, 559 U.S. 133, 140
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`(2010), with the intent to interfere with abortion inside the clinic, §
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`248(a)(1). But it is also quintessential reckless force. See Voisine, 579 U.S.
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`at 693-94 (recklessness includes “slamming [a] door shut with [one’s] girl-
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`friend following close behind . . . regardless of whether he thinks it abso-
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`lutely sure or only quite likely that he will catch her fingers in the jamb”).
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`Thus the hypotheticals, too, confirm Handy’s position.
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`10
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`USCA Case #23-3143 Document #2016974 Filed: 09/14/2023 Page 11 of 16
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`E. The Extra-Statutory Documents Support Ms. Handy.
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`Assuming arguendo this Court looks beyond the statute, which it
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`should not do, the record confirms Ms. Handy could have been convicted
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`for reckless force.
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`The Government notes the jury instructions defined “force” as
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`“power and/or violence exerted upon or against a person or property.” (Br.
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`15.) But that instruction did not match the “crime of violence” definition
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`for at least two reasons.
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`First, the instruction does not specify that reckless force was not
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`sufficient. Notably, four Justices of the U.S. Supreme Court recently
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`opined that use of force “against another” necessarily includes “reckless”
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`force—but they were in the dissent. See Borden, 141 S. Ct. at 1838 (Ka-
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`vanaugh, J., dissenting). It is easy to see that many jurors could likewise
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`conclude that force “against another” includes reckless force, without be-
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`ing instructed otherwise. And they were not so instructed here.
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`Second, the instruction allowed conviction for force against “prop-
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`erty,” without specifying that it be another’s property, despite that being
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`a requirement for a categorical “crime of violence.” See 18 U.S.C. §
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`3156(a)(4)(A) (“…property of another”).
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`11
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`USCA Case #23-3143 Document #2016974 Filed: 09/14/2023 Page 12 of 16
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`The Superseding Indictment also supports Handy’s position. It
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`shows her “force” conviction was sought based on either allegedly “force-
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`fully push[ing] through the Clinic door into the Clinic’s waiting room,”
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`along with several others, or allegedly aiding and abetting Defendant
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`Smith who “forcefully backed into the clinic, [] caus[ing] Nurse K to stum-
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`ble and sprain her ankle.” ECF No. 113, ¶¶22, 23. These are classic alle-
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`gations of recklessness—using force in “conscious[] disregard[]” of a
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`substantial and unjustifiable risk that “deliberate[ly] . . . endanger[s] an-
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`other,” without any evidence of a “conscious[] desire” to cause harm.
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`Counterman, 143 S. Ct. at 21117.3
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`Accordingly, the modified categorical approach also supports
`
`Handy, and her misdemeanor “force” conviction was not a “crime of vio-
`
`lence.”
`
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`
`
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`3 To be sure, Handy intends to appeal on the merits from these convictions,
`including the notion that she aided and abetted in separate conduct by another
`defendant that resulted in an (apparently incidental) injury, without any evi-
`dence that she specifically intended that conduct. Rosemond v. United States,
`572 U.S. 65, 71, 76 (2014). Further, courts have held that conspiracy is not
`itself a “crime of violence.” United States v. Bonner, 826 F. App’x 52, 56 (2d Cir.
`2020); Jones v. United States, 39 F.4th 523, 526 (8th Cir. 2022).
`12
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`USCA Case #23-3143 Document #2016974 Filed: 09/14/2023 Page 13 of 16
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`F. The Government’s “Violent Physical Obstruction” Ar-
`gument Fails Basic Logic and Practice.
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`The Government obstinately insists that any “physical obstruction”
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`that is not “exclusively nonviolent physical obstruction” punished sepa-
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`rately under § 248(b)(2) is necessarily “violent physical obstruction,” in-
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`cluding for a “physical obstruction” violation punished under subsection
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`(b)(1). (Br. 12, 17, 19.) But the Government simply ignores Handy’s argu-
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`ment that nonviolent physical obstruction can also receive the heightened
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`punishment under subsection (b)(1) so long as it was committed in addi-
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`tion to “force” or “threat” of force. Thus the crime would not involve “ex-
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`clusively nonviolent physical obstruction,” but it could involve nonviolent
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`physical obstruction nonetheless. (Mot. 18-21.)
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`The Government’s position to the contrary fails basic logic, as noth-
`
`ing in the statute requires the inference it draws. The Government ig-
`
`nores Handy’s dual-offense hypothetical confirming her position (Mot.
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`18-19), as well as the facts of this case that also involve convictions for
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`both force and physical obstruction (which could include nonviolent phys-
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`ical obstruction plus force, and thus not “exclusively nonviolent physical
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`obstruction”).
`
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`13
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`USCA Case #23-3143 Document #2016974 Filed: 09/14/2023 Page 14 of 16
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`Thus, a misdemeanor “physical obstruction” violation is also not a
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`“crime of violence.”
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`Accordingly, Handy is being wrongfully detained under 18 U.S.C. §
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`3143(a)(2). And the Government does not dispute that she meets the
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`standard for release under § 3143(a)(1).
`
`CONCLUSION
`
`The Supreme Court has recognized that “crime of violence” re-
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`strictions are intended to address “the special dangers” attendant to “vi-
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`olent criminal[s].” Borden, 141 S. Ct. at 1830 (emphasis added). Ms.
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`Handy’s misdemeanor FACE convictions recounted above hardly make
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`her a violent criminal. Accordingly, for the foregoing reasons, this Court
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`should reverse the District Court and free Ms. Handy pending sentenc-
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`ing.
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`14
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`USCA Case #23-3143 Document #2016974 Filed: 09/14/2023 Page 15 of 16
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`Respectfully submitted,
`
`
`
`
`
`/s/Martin A. Cannon
`Martin A. Cannon, Esquire (Application for
`Admission Pending)
`Thomas More Society
`10506 Burt Circle, Suite 110
`Omaha, Nebraska 68114
`Email: mcannonlaw@gmail.com
`Phone: (402) 690-1484
`
`/s/Stephen M. Crampton
`Stephen Crampton, Esquire (Application for
`Admission Pending)
`P.O. Box 4506
`Tupelo, MS 38803
`Email: scrampton@thomasmoresociety.org
`Phone: (662) 662-255-9439
`
`/s/ Dennis E. Boyle
`Dennis E. Boyle, Esquire Boyle & Jasari
`1050 Connecticut Ave, NW Suite 500
`Washington, DC 20036
`dboyle@boylejasari.com
`Telephone: (202) 798-7600
`
`Counsel for Appellant
`
`
`Dated: September 14, 2023
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`
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`15
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`USCA Case #23-3143 Document #2016974 Filed: 09/14/2023 Page 16 of 16
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`CERTIFICATE OF SERVICE
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`I hereby certify that on this 14th day of September, 2023, I caused
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`the foregoing motion to be filed with the Clerk of Court for the United
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`States Court of Appeals for the D.C. Circuit using this Court’s CM/ECF
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`system, which will serve all counsel of record.
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`/s/ Dennis E. Boyle
`Dennis E. Boyle
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`ADDENDUM
`CERTIFICATE OF PARTIES
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`Pursuant to D.C. Circuit Rules 27(a)(4) and 28(a)(1), Defendant-Ap-
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`pellant Lauren Handy hereby certifies that the parties that appeared in
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`the district court and that are now before this Court are Lauren Handy
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`(defendant-appellant) and the United States (appellee).
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`CERTIFICATE OF LENGTH
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`
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`I hereby certify that this Reply complies with the type-volume lim-
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`itation of D.C. Circuit Rule 27(d)(2)(A). Appellant’s Motion contains 2,539
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`words.
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`/s/Dennis E. Boyle
`Dennis E. Boyle
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`16
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