Summary of Opinion

Factual and Procedural Background

Edward Reed was convicted on October 20, 1967, after a jury trial of larceny under the federal bank robbery statute, 18 U.S.C. § 2113, for his role as one of three armed men who robbed the Allingtown Branch of the First New Haven National Bank. The Court's earlier memorandum of December 22, 1967, contains the facts of the offense.

On January 8, 1968, Reed was sentenced to nine years' imprisonment. At sentencing the government moved under 18 U.S.C. § 3148 to hold Reed without bond pending appeal, arguing he was a danger to the community (but not that he would flee). The Court initially denied the government's motion, noting competing interests: the time necessary to process an appeal and that the defendant's appellate questions were not frivolous, weighed against Reed's extensive criminal record and demonstrated disrespect for authority.

The Court warned Reed that his bond could be revoked easily if his conduct warranted it. Subsequent events included: (1) a grand jury indictment on January 22, 1968, charging Reed with robbing the Long Wharf Branch of the First New Haven National Bank on January 19, 1967; (2) on January 16, 1968, Reed pleaded guilty in state court to breach of the peace and abusing a police officer, which involved a threat upon the life of an East Haven police officer; and (3) on February 2, 1968, Reed was arrested for motor vehicle offenses (operating without a license and unsafe lane changes).

Based on these developments, the government renewed its motion to revoke bond. The Court concluded the government had sustained its burden to show Reed represented a danger to the community and revoked his $35,000 bond, ordering Reed to surrender to the United States Marshal in New Haven not later than March 8, 1968, at 5:00 P.M.

Legal Issues Presented

1. Whether the defendant's bond should be revoked under 18 U.S.C. § 3148 because he represents a danger to the community.

Arguments of the Parties

Government's Arguments

• The government moved under 18 U.S.C. § 3148 to hold the defendant without bond pending appeal, arguing that Reed represented a danger to the community. The government did not assert that Reed would flee jurisdiction.

Defendant's Position

• The opinion notes that the questions Reed sought to raise on appeal were not frivolous, which the Court considered in initially denying the government's motion, but the opinion does not provide a detailed account of the defendant's legal arguments opposing revocation.

Table of Precedents Cited

No precedents were cited in the provided opinion.

Court's Reasoning and Analysis

The Court balanced competing considerations under the statute invoked by the government. It recognized the legitimate interest in allowing time for an appeal and observed that Reed's appellate issues were not frivolous, which weighed against immediate detention without bond. Opposing that, the Court emphasized Reed's substantial prior criminal record and demonstrated disrespect for authority as indicia of dangerousness. At the initial January 8 hearing the Court found the defendant's record significant but, on balance, denied the government's motion while expressly warning Reed that further misconduct could result in revocation of bail.

After the January 8 hearing, additional conduct occurred: a new federal indictment for another bank robbery, state guilty pleas for breach of the peace and abusing an officer (including a threat on an officer's life), and subsequent state arrests for motor vehicle offenses. The Court found these further incidents sufficient for the government to meet its burden under 18 U.S.C. § 3148 to show that Reed posed a danger to the community. Based on that showing, and consistent with its earlier warning, the Court concluded revocation of bond was appropriate.

Holding and Implications

Bond revoked.

Direct effect: The defendant's $35,000 bond was revoked, and Edward Reed was ordered to surrender to the United States Marshal at the United States Courthouse in New Haven, Connecticut, by March 8, 1968, at 5:00 P.M.

Broader implications: The opinion does not discuss or establish any new legal precedent; its decision applies the statutory standard for revocation under the circumstances involving the defendant's post-sentencing conduct and extensive criminal history.