Harboring18 USC 1071Fourth Element --
Discovery or Arrest
The final element that must be established in a Section 1071
is that the defendant harbored or concealed the fugitive "so as to prevent
discovery and arrest." This element is satisfied principally by inference
the evidence offered to prove that the defendant harbored or concealed the
fugitive. For example, the Fourth Circuit in United States v.
F.2d 840, 849 (1982), cert. denied, 470 U.S. 1031 (1985) concluded
renting a room for the fugitive and supplying him with guns and disguises
"clearly the type of assistance which would aid a fugitive" in avoiding
and apprehension. In addition, Section 1071 does not require a showing of
by the defendant to prevent, for all time, the discovery and arrest of the
fugitive. United States v. Bissonette, 586 F.2d 73, 78 (8th Cir.