WASHINGTON – A divided federal appeals court panel has upheld an interstate kidnapping conviction that stemmed from the 1998 second-degree murder of a Prince George’s County woman.
The two-judge majority on the 4th U.S. Circuit Court of Appeals rejected James Horton’s argument that he did not violate the Federal Kidnapping Act because Jovita Dickerson was kidnapped and killed in Maryland, before her body was driven across state lines to North Carolina.
But in a dissenting opinion, Circuit Judge M. Blane Michael wrote that Horton, 26, deserved a new trial because the lower court did not allow the jury to determine at what point the interstate transportation of the victim began.
Michael wrote that the majority opinion “erroneously sweeps in (to federal jurisdiction) a kidnapping that is begun and ended in one state, but is followed at some point by the movement of the victim’s body across state lines.”
Court documents said the case began in November 1998 when Stephen Satcher, 30, offered cousin Daniel Stancil some cocaine in exchange for his help kidnapping Dickerson, the mother of Satcher’s child. Horton later agreed to help Stancil.
On Dec. 4, 1998, the three men waited for Dickerson to leave work in Bowie. Horton used a toy gun to force her into her car, which they drove to a house in Cheverly.
At the house, Satcher and Stancil tried to kill Dickerson before Horton went to “finish her off” on the third try, according to court records. Stancil later testified that Dickerson “looked dead” when Satcher and Horton loaded her body in the trunk of a car.
After putting the body in the car, Horton and Stancil drove to North Carolina and spent the night in a hotel. The next morning they took the car to a field and set it on fire with the body still in the trunk.
Horton was charged with the murder in North Carolina rather than Maryland because the body was burned so badly that the time and location of her death could not be determined.
He was convicted of a state charge of second-degree murder and federal charges of conspiracy to commit kidnapping and kidnapping resulting in death. He was sentenced to just under 52 years in prison for the murder conviction and life without parole on the federal charges, law enforcement officials said Wednesday.
Satcher is serving a life sentence in federal prison, according to the Bureau of Prisons web site. Stancil pleaded guilty to conspiracy, but his sentence could not be determined Wednesday.
Horton argued that the “transportation” of Dickerson across state lines began when they loaded her body in the trunk with the intention of taking it to North Carolina, and that the trial court was wrong to tell jurors that it began with the Bowie abduction.
But the appeals court said there is “no basis” for that argument. In a published opinion Monday, the majority said that interstate transportation begins with the first point of abduction, “even when the path from the place of abduction to the state line is not straight.”
Horton’s attorney, Thomas J. Saunders, said he had not conferred with his client, but that he likely will ask the entire circuit court to review Monday’s ruling.
“I believe that with the way the Supreme Court has been ruling on the separation of powers, the dissent view will be correct,” Saunders said.
Horton is currently working as a cook in the Pasquotank Correctional Institute in North Carolina where he is serving his sentence for second-degree murder, said Pam Walker, a prison spokeswoman.