United States v. Lin

United States Court of Appeals for the District of Columbia Circuit · 1996 · Evidence

101 F.3d 760 (D.C. Cir. 1996)

Updated August 22, 2026

Evidence18 U.S.C. § 120318 U.S.C. § 924(c)hostage takingthird person compulsionnon-nationality requirementcross-examinationbias impeachment

Facts

Lin, Gao, and others took Chen and Li from a Chinatown apartment at gunpoint to Lin and Gao's residence, where the two men were handcuffed, beaten, and questioned about tapped telephone lines. The captors demanded $10,000, then told the hostages to get relatives to borrow money or guarantee payment, which led to Guan Huan Chen being summoned to negotiate. The captors kept Chen and Li out of sight in the basement and did not release them until Guan Huan Chen negotiated a payment amount and agreed to pay for their release; the hostages paid part immediately and Guan Huan Chen paid the balance over the next five days. None of the hostage takers or hostages were United States nationals.

Issue

Whether the Hostage Taking Act applied to this entirely local seizure involving only non-United States nationals, and whether the evidence was sufficient to prove that Lin and Gao detained the victims to compel a third person to pay for their release. The court also considered whether limiting cross-examination of Guan Huan Chen and allowing testimony that arguably bolstered government witnesses required reversal, and whether Lin's § 924(c) convictions could stand after Bailey.

Rule

Under 18 U.S.C. § 1203, the offense consists of (1) seizing or detaining another person, and (2) threatening to kill, injure, or continue to detain that person, (3) for the purpose of compelling a third person or governmental organization to do or abstain from doing any act as a condition of release. The Act applies according to its plain language and covers domestic conduct when the statutory exemption does not apply; if even one offender or detainee is not a United States national, the exemption for purely domestic incidents is unavailable. A trial court may limit highly prejudicial cross-examination aimed at bias unless counsel has some factual basis supporting a genuine belief in the misconduct implied, and a § 924(c) "use" conviction requires active employment of the firearm, not mere availability or possession.

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One of 10 multiple-choice questions for this case. Pick an answer to see why.

At a federal robbery trial in Baltimore, defense counsel wants to ask the government's main eyewitness, Omar Vega, whether he runs an illegal sports-betting room and framed the defendant to eliminate competition. Counsel says only that the defendant told her "everyone knows" Vega does this, and she offers no documents, other witnesses, or prior testimony supporting the accusation.

Should the trial judge permit the question as bias impeachment?

Explanation. The majority held that bias is generally relevant, but counsel must have a reasonable basis before asking questions that incriminate or degrade a witness. A vague assertion based only on the defendant's unsupported accusation is insufficient for a highly prejudicial line of questioning.