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

laying out detailed criteria for severance based on 26 codefendant testimony | laying out detailed criteria for severance based on 26 codefendant testimony | 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”