United States v. Carmenate

Defendant Pedro Carménate appeals from a judgment of conviction, following a bench trial, in the United States District Court for the Southern District of New York (Kenneth M. Karas, Judge) on one count of bank fraud, in violation of 18 U.S.C. § 1344. On appeal, defendant argues that the District Court violated defendant’s constitutional right to a jury trial in a criminal case because (1) defendant never signed a written jury waiver pursuant to Rule 23(a) of the Federal Rules of Criminal Procedure, and (2) his oral waiver of his right to a jury trial was not knowing, voluntary, or…