United States v. Stephen Michael Saniti

Saniti was convicted of bank robbery pursuant to 18 U.S.C. § 2113(a). We affirm.

Relying upon Hawkins v. United States, 358 U.S. 74, 79 S.Ct. 136, 3 L.Ed.2d 125 (1958), Saniti contends that the district court committed reversible error when it compelled his wife to testify against him. Even assuming the legal issue was properly raised in this case, there is a narrow exception to the husband-wife privilege when the marriage is not entered into in good faith. See Lutwak v. United States, 344 U.S. 604, 73 S.Ct. 481, 97 L.Ed. 593 (1953); United States v. Mathis, 559 F.2d 294, 298 (5th Cir. 1977).…