United States v. Brown

TORRUELLA, Circuit Judge.

Defendant-appellant Steven K. Brown pled guilty to nine offenses, including kidnapping in violation of 18 U.S.C. § 1201(a)(1). On appeal, Brown seeks to vacate his kidnapping conviction, arguing that the indictment failed to allege a necessary element of the kidnapping offense under which he was sentenced. Even assuming the indictment was wanting in some regard, Brown’s appeal must fail because he cannot demonstrate that the indictment’s error prejudiced him. We therefore affirm his conviction.

FACTUAL BACKGROUND

Armed with knives, a shotgun, and an assault rifle,…