## Facts

- William Bell and Lenard Dixon were federal inmates housed in Unit E–1 at the U.S. Penitentiary in Terre Haute, Indiana; they shared a cell, and Brian Pendleton lived two cells away.
- Surveillance cameras recorded common areas outside cells, allowing the jury to view movements on the range but not the cell interiors when doors were closed.
- Video showed Bell walking from his cell to Pendleton’s cell with his right hand held in his pants pocket as if holding an object; he opened Pendleton’s door with his left hand, entered, and closed the door.
- Dixon soon left the shared cell and sat outside Pendleton’s cell, facing away but repeatedly looking toward the cell.
- About 70 seconds later, Bell exited Pendleton’s cell shirtless, carrying a white shirt wrapped around a long, slender object, and returned to his own cell.
- Dixon briefly entered Pendleton’s cell and exited; Pendleton then crawled into the range bleeding heavily from the neck.
- Dixon stepped around or over Pendleton without rendering aid, carried items appearing to include clothing and a sharpened rod, placed them in a dayroom trash can, and covered them with other trash.
- Bell later appeared wearing a white shirt again and walked calmly to the shower area; investigators observed no signs of a struggle in Pendleton’s cell.
- An autopsy found Pendleton died from a single deep stab wound to the neck severing major blood vessels, consistent with a long, slender sharp object.
- The government introduced evidence of an inculpatory statement by Bell concerning the killing.

## Issues

1. Whether evidence was sufficient to prove beyond a reasonable doubt that Bell committed first-degree murder by acting with premeditation under 18 U.S.C. § 1111(a).
2. Whether evidence was sufficient to prove Dixon was an accessory after the fact under 18 U.S.C. § 3, including intent to help Bell avoid apprehension or punishment.
3. Whether the district court abused its discretion by admitting Bell’s inculpatory statement.
4. Whether trying Dixon in leg shackles denied him a fair trial.

## Decision

- The court affirmed Bell’s first-degree murder conviction and Dixon’s accessory-after-the-fact conviction.
- The court held the evidence permitted a rational jury to find Bell acted with premeditation, including evidence suggesting he arrived armed, inflicted a lethal neck wound, and acted calmly afterward with efforts consistent with concealment.
- The court held the evidence permitted a rational jury to find Dixon knew of the murder and acted with the intent to hinder Bell’s apprehension, including acting as a lookout and disposing of suspected weapon-related items.
- The court found no abuse of discretion in admitting Bell’s inculpatory statement, particularly given corroboration from video and physical evidence.
- The court found no abuse of discretion in the decision to shackle Dixon at trial where security considerations were addressed and visibility was limited, and Dixon did not show prejudice warranting reversal.

## Legal Principles

- Premeditation under 18 U.S.C. § 1111(a) does not require extended planning; it may be formed quickly if the defendant had an opportunity for reflection before acting.
- Premeditation may be inferred from circumstantial evidence, including the nature and location of wounds, conduct before and after the killing, and surrounding events.
- Accessory-after-the-fact liability under 18 U.S.C. § 3 requires proof the defendant knew of the principal offense and intentionally assisted the offender to prevent arrest, trial, or punishment; concealment of evidence can support the required intent.
- Appellate review of sufficiency claims asks whether any rational jury could find the elements proved beyond a reasonable doubt when viewing evidence in the government’s favor.
- Evidentiary rulings are reviewed for abuse of discretion; corroboration and overall fairness of the trial inform whether admission warrants reversal.
- Visible restraints are generally disfavored, but a trial court may impose restraints for security reasons within its discretion if precautions limit prejudice.

## Conclusion

The Seventh Circuit upheld convictions arising from a prison killing, concluding that the surveillance footage and related evidence supported findings of premeditated first-degree murder by Bell and intentional post-crime assistance by Dixon, and that the challenged evidentiary and security-related trial rulings did not justify reversal.


United States v. Bell, 819 F.3d 310 (7th Cir. 2016)