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Crime Victims' Rights During Criminal Investigations? Applying the Crime Victims' Rights Act Before Criminal Charges Are Filed
victims were treated in all stages of the criminal justice process, from the police investigation through 6 See DoucLAs E. BELoor, PAUL G. CASSELL & STEVEN J. Twist, VICTIMS IN CRIMINAL PROCEDURE 3-39 (3d ed. 2010) (describing reforms from a historical perspective), see also, e.g., 18 U.S.C. § 3771(a) (2012). T
Page: HOUSE_OVERSIGHT_014042 →rts concluded that a victim of uncharged conduct should not be afforded statutory protections.'°! Yet none of these cases—United States v. Turner,'°? Searcy v. Paletz,'® or Searcy v. Skinner'°*—provide strong support for OLC’s position. Turner is a particularly poor fit. Although OLC’s memorandum characte
Page: HOUSE_OVERSIGHT_014057 →CRIMINAL LAW: CRIME VICTIMS' RIGHTS DURING CRIMINAL INVESTIGATIONS? APPLYING THE CRIME VICTIMS' RIGHTS ACT BEFORE CRIMINAL CHARGES ARE FILED
y parole or other release of the criminal. The Task Force 4 18 U.S.C. § 3771(¢)(1). > Id. § 3771(d)(3). © See Douglas E. Beloof, Paul G. Cassell & Steven J. Twist, Victims in Criminal Procedure 3-39 (3d ed. 2010) (describing reforms from a historical perspective); see also, e.g., /8 U.S.C. § 377/(a) (2012). 7
Page: HOUSE_OVERSIGHT_017606 →that a victim of uncharged conduct should not be afforded statutory protections. !°! Yet none of these cases - United States v. 10 104 Turner, !9? Searcy v. Paletz, !°3 or Searcy v. Skinner - provide strong support for OLC's position. Turner is a particularly 9 See 42 U.S.C. § 10607(c). % Td. § 10607(
Page: HOUSE_OVERSIGHT_017616 →ARTICLE: Treating Crime Victims Fairly: Integrating Victims into the Federal Rules of Criminal Procedure
yne v. Tennessee, 501 U.S. 808, 834 (1991) (Scalia, J., concurring) (internal quotations omitted). See generally Douglas E. Beloof, Paul G. Cassell & Steven J. Twist, Victims in Criminal Procedure 638-39 (2d ed. 2005) (discussing the need for victims’ participation in the criminal justice system); see also Shirley
Page: HOUSE_OVERSIGHT_017638 →ainst individuals who have not been convicted of a crime." Jn re W.R. Huff Asset Mgmt. Co., 409 F.3d 555, 564 (2d Cir. 2005) (emphasis added); accord Searcy v. Skinner, No. 6:06-1418-GRA-WMC, 2006 WL 1677177, at 2 (D.S.C. June 16, 2006). Like the constitutional amendment it was patterned on, the CVRA exte
Page: HOUSE_OVERSIGHT_017708 →Entities connected to both Searcy and Steven J. Twist

Jeffrey Epstein
PERSON
Bradley Edwards
PERSONScott Rothstein
PERSON
George W. Bush
PERSONJane Doe
PERSON
Paul Cassell
PERSON
United States
LOCATIONMaria Farmer
PERSON
Donald Trump
PERSON
Prince Andrew
PERSON
Salt Lake City
LOCATION
A. Marie Villafana
PERSON
Jay Howell
PERSON
Bill Clinton
PERSON
Alexander Acosta
PERSON
Department of Justice
ORGANIZATION
S.J. Quinney College of Law
ORGANIZATION
Supreme Court
ORGANIZATION
the University of Utah
ORGANIZATIONCriminal Division
ORGANIZATION