United States v. Frazier

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PMC, an “outlaw” motorcycle club that has existed since 1968, has chapters in Michigan, Ohio, and six other states. PMC has a hierarchical structure, with a national president, vice president, and enforcers. Members wear leather vests, known as “rags,” to display the member’s club and that club’s territory. PMC competes with rival outlaw clubs to be the dominant club within certain territories. Following a shooting during an altercation with a rival gang and after interrupting a plan for retaliation, the government charged Frazier, Odum, and 12 others in a 15-count indictment., Frazier and Odum were severed, and the case against them proceeded separately. A jury convicted Frazier of two counts of assault with a dangerous weapon in aid of racketeering, 18 U.S.C. 1959(a)(3), and one count of use and carry of a firearm during, and in relation to, a crime of violence, 18 U.S.C. 924(c). Odum was convicted of conspiracy to commit murder in aid of racketeering, 18 U.S.C. 1959(a)(5). The Sixth Circuit affirmed, rejecting claims of insufficient evidence to sustain their convictions, improper venue, improper admission of hearsay statements, and due process violations for failure to call a witness or provide certain evidence to the defense. View "United States v. Frazier" on Justia Law