United States v. Whitt Snow

BAZELON, Chief Judge:

Whitt Snow was found guilty of escaping from a Department of Corrections halfway house on 13th Street, N. W.1 Snow waived his right to a jury trial and was tried before a judge alone. In such circumstances, Rule 23 of the Federal Rules of Criminal Procedure requires the court to enter findings of fact to support its verdict.2 No findings were entered in this case. Although the trial judge directed the prosecutor to prepare the findings for the court’s approval, the prosecutor apparently never did so.

This error frustrates our review of the case. Snow’s main argument on…