United States v. Modanlo

Brief for National Association of Criminal Defense Lawyers as Amicus Curiae in Support of Appellant and Reversal.

Brief filed: 05/29/2015


United States v. Modanlo

4th Circuit Court of Appeals; Case No. 14-4044

Prior Decision

Appeal from the United States District Court for the District of Maryland in Case No. 8:10-cr-00295-PJM (Mesitte, J.).


Ex Parte communications are highly disfavored. The district court failed to determine whether ex parte communications were made necessary by concerns for "national security," and whether such communications would violate the defendant's constitutional rights.

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Paul F. Enzinna, Rahman Connelly, Brown Rudnick LLP, Washington, DC; David B. Smith, Smith & Zimmerman, PLLC, Alexandria, VA.