United States v. Michael Sean Gianakos

SMITH, Circuit Judge.

A federal jury found Michael Sean Gia-nakos guilty of kidnapping with death resulting, in violation of 18 U.S.C. § 1201(a)(1). The district court1 sentenced him to life imprisonment. Michael appeals his conviction on numerous grounds: (1) the district court should not have admitted his state-court testimony at trial; (2) the court erred in refusing to instruct the jury with regard to the offense of accessory after the fact and granting him a new trial; (3) the district court erred in failing to adequately address juror misconduct; (4) the court abused its discretion by…