UNITED STATES OF AMERICA v. ERIK CHARLES MAUND; BRYON BROCKWAY; ADAM CAREY - Articles

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Posted by: Azya Thornton on Feb 23, 2026

Court: 6th Circuit Court (Published Opinions)

Attorneys 1: ARGUED: Nicholas J. Goldin, UNITED STATES ATTORNEY’S OFFICE, Nashville, Tennessee, for Appellant.

Attorneys 2: ARGUED: David M. Gonzalez, SUMPTER & GONZÁLEZ, L.L.P., Austin, Texas, for Appellee Maund.

Attorneys 3: Luke A. Evans, FIOLA PARKER, Murfreesboro, Tennessee, for Appellee Brockway. Benjamin H. Perry, LAW OFFICE OF BENJAMIN H. PERRY, Nashville, Tennessee, for Appellee Carey.

Attorneys 4: ON BRIEF: Nicholas J. Goldin, Robert E. McGuire, Rascoe Dean, Brooke Carey Farzad, UNITED STATES ATTORNEY’S OFFICE, Nashville, Tennessee, for Appellant.

Attorneys 5: ON BRIEF: David M. Gonzalez, SUMPTER & GONZÁLEZ, L.L.P., Austin, Texas, Samuel E. Bassett, Perry Q. Minton, MINTON, BASSETT, FLORE & CARSEY, Austin, Texas, John-David H. Thomas, BARNES & THORNBURG, L.L.P., Nashville, Tennessee, for Appellee Maund.

Attorneys 6: ON BRIEF: Luke A. Evans, FIOLA PARKER, Murfreesboro, Tennessee, for Appellee Brockway. Benjamin H. Perry, LAW OFFICE OF BENJAMIN H. PERRY, Nashville, Tennessee, John Bailey, Brentwood, Tennessee, for Appellee Carey.

Judge(s): MOORE, THAPAR, and RITZ, Circuit Judges

Court Appealed: United States District Court for the Middle District of Tennessee at Nashville

RITZ, Circuit Judge. A jury convicted Erik Maund, Adam Carey, and Bryon Brockway of various offenses related to a murder-for-hire. During jury deliberations, however, the district court inadvertently gave the jury several unadmitted exhibits and failed to provide some of the admitted exhibits. The district court only realized its error months after the verdict. Upon receiving notice of the error, defendants each moved for a new trial. After a hearing to determine the jury’s exposure to the unadmitted exhibits, the district court found its error to be structural and granted a new trial. The government appealed, arguing that the error was not structural, the harmless-error standard applies instead, and the error was harmless. We agree and reverse.

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