United States v. Joseph George Helmich

RONEY, Circuit Judge:

Serving a life sentence, Joseph George Helmich appeals his conviction for conspiracy to commit espionage. 18 U.S.C.A. § 794(c). Helmich pled guilty to the conspiracy charge, and the government dismissed three substantive counts. The defendant argues on appeal two issues not foreclosed by the guilty plea: first, the statute of limitations was a jurisdictional bar to the indictment and second, Wharton’s Rule prevented his prosecution for conspiracy because it was duplicitous of the substantive charge of espionage. We affirm.

With respect to the statute of limitations issue,…