United States v. Riffe

Leonard Riffe (defendant), a prison inmate, smuggled marijuana into his facility with his girlfriend's help under threats from a prison gang demanding drugs as debt repayment, including threats to kill him if he refused. At trial, Riffe presented evidence, including his own and a fellow inmate's testimony, that seeking help from prison officials would have exposed him to greater danger, since officials would have forced him to identify the gang members. The district court refused a duress instruction, finding Riffe hadn't met the Singleton test's requirement of no reasonable legal alternative, treating that requirement as a rigid rule that Riffe had to show he'd actually sought help from officials, and Riffe was convicted and appealed.