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Vindictive Prosecution

By: WISCONSIN LAW JOURNAL STAFF//June 5, 2023//

Vindictive Prosecution

By: WISCONSIN LAW JOURNAL STAFF//June 5, 2023//

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7th Circuit Court of Appeals

Case Name: United States of America v. Angela Baldwin

Case No.: 22-1835

Officials: Scudder, Kirsch, and Lee, Circuit Judges.

Focus: Vindictive Prosecution

Russell Taylor and Angela Baldwin, then husband and wife, came to the government’s attention thanks to an investigation into Jared Fogle’s sexual exploitation of young girls. Angela Baldwin and her then-husband, Russell Taylor, sexually exploited four girls, including her two daughters and her niece. They conspired to produce and distributed explicit videos—some secretly recorded—of the girls. She sexually assaulted three of them. A jury convicted her of those crimes. She contends that her prosecution was vindictive and that her sentence is excessive. Neither contention has merit. Baldwin’s indictment was five years after Taylor was first indicted. Waiting to build a stronger case before pursuing an indictment is evidence of responsible, rather than vindictive, government behavior. Taylor’s success in vacating his original conviction stemmed from his counsel’s incompetence, not missteps by the government.

Affirmed.

Decided 05/30/23

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