Seventh Circuit -- USA v. Wosvaldo Villegas

USA v. Wosvaldo Villegas

   Meeting with conspirators, bringing tools for the job, and planning to meet again is sufficient for a substantial step under the Hobbs Act. 

Sufficient evidence that deft took a substantial step under Hobbs Act where he met with co-conspirators, brought license plates to be used, and planned another meeting.  Recorded phone conversations suffice to establish threats of violence.

No error in not giving missing witness instruction where witness was available to deft, despite tension with defense team.  Additionally, deft was permitted to refer to the no-call many times in closing.

No error in introduction of evidence on priors as deft opened door.

No error in sentencing bump for brandishing weapon, as it was foreseeable and foreseen.  The fact that the CI did it is not relevant.