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Manuel Enrique Santana v. United States

Paid petition · United States Court of Appeals for the Eleventh Circuit, No. 17-11930 · judgment June 25, 2018


Certiorari denied · April 1, 2019
Pre-decision estimate: 9% cert probability (95% interval 6%–13%)

Before the decision, about 2.1× the 4.1% base rate. The model weighted this up for counsel who has won certiorari before, a circuit split argued in the petition, and an Eleventh Circuit decision below.

Question presented

The federal aggravated identity theft statute imposes an additional mandatory two-year prison sentence on anyone who “knowingly transfers, possesses, or uses, without lawful authority, a means of identification of another person” during and in relation to specified felony offenses. 18 U.S.C. § 1028A(a)(1). Under the statute, “means of identification” is defined as “any name or number that may be used, alone or in conjunction with any other information, to identify a specific individual.” Id. § 1028(d)(7) (emphasis added). There is an acknowledged conflict among the courts of appeals as to whether a defendant’s use of a person’s name—be it typed or handwritten—constitutes the “use[]” of a “means of identification” under the aggravated identity theft statute. The question presented is: Whether the use of a name, without more, constitutes the use of a “means of identification of another person” under 18 U.S.C. § 1028A.

Counsel of record

For petitioner
Andrew John Pincus
Mayer Brown LLP

For respondent
Noel John Francisco
Jones Day

Case

Conference history
Distributed for 1 conference

Linked docket
18A273

Proceedings

  1. Apr 01 2019
    Petition DENIED.
  2. Mar 13 2019
    DISTRIBUTED for Conference of 3/29/2019.
  3. Mar 12 2019
    Reply of petitioner Manuel Enrique Santana filed. (Distributed)
  4. Feb 25 2019
    Brief of respondent United States in opposition filed.
  5. Jan 07 2019
    Motion to extend the time to file a response is granted and the time is further extended to and including February 25, 2019.
  6. Jan 03 2019
    Motion to extend the time to file a response from January 25, 2019 to February 25, 2019, submitted to The Clerk.
  7. Dec 19 2018
    Motion to extend the time to file a response is granted and the time is extended to and including January 25, 2019.
  8. Dec 18 2018
    Motion to extend the time to file a response from December 26, 2018 to January 25, 2019, submitted to The Clerk.
  9. Nov 21 2018
    Petition for a writ of certiorari filed. (Response due December 26, 2018)
  10. Sep 18 2018
    Application (18A273) granted by Justice Thomas extending the time to file until November 22, 2018.
  11. Sep 14 2018
    Application (18A273) to extend the time to file a petition for a writ of certiorari from September 23, 2018 to November 22, 2018, submitted to Justice Thomas.