United States v. Andino
This case involved defendant David Andino, who was charged with conspiring and attempting to commit murder for hire under 18 U.S.C. § 1959(a), and related firearm charges under 18 U.S.C. § 924(c). Andino was accused of helping the drug gang Sex, Money and Murder (SMM) locate and shoot Domingo Osorio in exchange for money. Following a mistrial, Andino renewed his motion for a judgment of acquittal. The court found insufficient evidence to prove that Andino expected or received payment from SMM, as required by the 'murder for hire' provision. Specifically, the prosecution failed to demonstrate that John Castro, who paid Andino, acted on behalf of the SMM enterprise rather than in a personal capacity. Consequently, the court granted Andino's motion for a judgment of acquittal on all charges due to the lack of evidence for an essential element of the crimes.