USA v. Wyatt et al

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UNITED STATES DISTRICT COURT
FOR THE SOUTHERN DISTRICT OF OHIO
WESTERN DIVISION AT DAYTON
UNITED STATES OF AMERICA,
Plaintiff,
v.
DEVONTE WYATT et al.,
Defendants.
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Case No. 3:25-cr-00054
Judge Thomas M. Rose
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ENTRY AND ORDER MEMORIALIZING HEARING, GRANTING
DEFENDANT VAUGHN’S MOTION IN LIMINE (DOC. NO. 47), AND
GRANTING GOVERNMENT’S MOTION IN LIMINE (DOC. NO. 48)
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On March 3, 2026, the Court held a hearing regarding Defendant Dalan Vaughn’s
(“Vaughn”) Motion in Limine (“Vaughn’s Motion”) (Doc. No. 47), along with the Government’s
Motion in Limine (“Government’s Motion”) (Doc. No. 48) (collectively, the “Motions”). This
Order serves to memorialize said hearing and dispose of the aforementioned Motions.
On February 16, 2026, Vaughn filed his Motion, requesting that the Court “exclude from
evidence at trial all evidence referring or relating to [] Vaughn derived from the bifurcated nature
of the pretrial disclosure of evidence by the Government.” (Doc. No. 47 at PageID 299.) In other
words, Vaughn seeks exclusion of any evidence referencing Vaughn found in the discovery only
provided to Devonte Wyatt (“Wyatt”), Vaughn’s co-defendant. (Id. at PageID 299–300.) The
Government responded to Vaughn’s Motion on February 19, 2026. (See Doc. No. 49.) In its
Response, the Government assures Vaughn that “it does not intend to impute or suggest that any
evidence arising from or derived from the evidence disclosed only to [] Wyatt will necessarily be
imputed to [] Vaughn.” (Id. at PageID 313.) At the hearing, neither Vaughn nor the Government
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put forth any further evidence to supplement their respective filings. Given the uncontested nature
of this matter, the Court sees no issue in limiting the Government’s evidence used to implicate
Vaughn to that which was disclosed to Vaughn during the discovery period. Accordingly, the
Court hereby GRANTS Vaughn’s Motion in Limine (Doc. No. 47).
On February 17, 2026, the Government filed its Motion in Limine (Doc. No. 48), by which
it seeks to admit evidence of an uncharged incident which occurred on December 6, 2023, along
with evidence gleaned from a search of Wyatt’s Instagram account. (Doc. No. 48 at PageID 309.)
For its primary argument in favor of admission, the Government maintains its proffered
evidence—the December 2023 event and the Instagram posts—qualifies as intrinsic evidence and
is therefore admissible.1 (Id. at PageID 305–06.) Alternatively, and in the event the Court were to
find the evidence extrinsic, the Government seeks to admit its proffered evidence pursuant to
Federal Rule of Evidence 404(b)(2). (Id. at PageID 307–09.) Neither Wyatt nor Vaughn filed a
response to the Government’s Motion. And at the hearing, neither the Government nor either
Defendant sought to supplement their positions with argument. Finding the Government’s Motion
well-taken, the Court hereby GRANTS the Government’s Motion in Limine (Doc. No. 48).
Accordingly, to memorialize the hearing held on March 3, 2026, the Court hereby
GRANTS Vaughn’s Motion in Limine (Doc. No. 47), GRANTS the Government’s Motion in
Limine (Doc. No. 48), and further FINDS as follows:
1. The Government is ORDERED to limit its trial evidence in its case against Vaughn to the
evidence produced to Vaughn during the discovery period.
1 The Government poses an alternative argument in favor of admitting res gestae evidence as one separate and distinct
from its argument advocating for admission of intrinsic evidence. (See Doc. No. 48 at PageID 306–07.) Because the
Sixth Circuit has treated these doctrines as one, the Court here does the same. See United States v. Gibbs, 797 F.3d
416, 423 (6th Cir. 2015) (“Res gestae evidence, also described as ‘background’ or ‘intrinsic’ evidence, is ‘an
exception’ to the Rule 404(b) bar on propensity evidence.” (quoting United States v. Adams, 722 F.3d 788, 810
(6th Cir. 2013))).
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2. The evidence for which the Government’s Motion seeks admission—namely, the
December 2023 event and evidence gleaned from the search of Wyatt’s Instagram
account—is ADMITTED as intrinsic evidence.
DONE and ORDERED in Dayton, Ohio, this Wednesday, March 4, 2026.
s/Thomas M. Rose
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THOMAS M. ROSE
UNITED STATES DISTRICT JUDGE
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