In United States v. Maldonado-Passage, — F.4th —, 2022 U.S. App. LEXIS 35541 (Dec. 23, 2022), the U.S. Court of Appeals for the Tenth Circuit upheld a 252-month sentence for Joseph “Tiger King” Maldonado-Passage based primarily on his conviction on two murder-for-hire schemes. The circuit court rejected two procedural and two substantive challenges to his new sentence imposed after a prior appeal and remand. In the process, the court ruled that his two schemes to murder one person constituted two separate offenses under 18 U.S.C. §1958(a), a federal statute that criminalizes the use of interstate travel or the facilities of interstate commerce in a murder-for-hire scheme.
Maldonado-Passage’s two murder-for-hire counts arose out of a dispute with Carol Baskin, an activist who felt he was mistreating animals in his Oklahoma zoo. Id. at *3. Their rivalry was featured in the 2020 Netflix documentary Tiger King: Murder, Mayhem, and Madness. Id. With respect to his first count, in November 2017, he solicited a zoo employee, Alan Glover, to kill Baskin; provided him with a phone preloaded with pictures of her; and organized and paid him $3,000 for his interstate travel to Florida to murder her. Id. at *4. Glover traveled from Oklahoma to Florida but didn’t try to kill her. Id.