Massa v. United States Court of Appeals for the Eighth Circuit

How later courts describe this case

• laying out detailed criteria for severance based on 26 codefendant testimony
• enumeration of specific exclusions from operation of statute is indication that statute should apply to all cases not specifically excluded
• all authorizing factspecific analysis of defendants’ actions to determine whether “crime of violence” definition was satisfied
• enough that the crime be committed against a vulnerable person
• affirming enhancement of kidnapping guideline on basis of extortion
• requiring a “clear showing of prejudicial abuse of discretion”
• district court’s determination of vulnerability entitled to “due deference”