The Denver-based federal appeals court upheld the 2022 convictions of Lawrence “Larry” Rudolph on Monday, who jurors found guilty of killing his wife on an African hunting trip years earlier.

Rudolph raised multiple contentions on appeal, including that he should have been tried separately from his co-defendant and mistress, Lori Milliron; that the trial judge allowed improper testimony; that Colorado was not the proper location for his trial; and that the judge excessively ordered Rudolph to turn over certain assets as part of his sentence.

A three-judge panel of the U.S. Court of Appeals for the 10th Circuit rejected all of those contentions. Deciding an issue for the first time within the circuit’s six-state region, the panel concluded that a defendant re-entering the country is deemed “arrested” in the location where he is detained in connection with an offense. In Rudolph’s case, he was deported from Mexico to Denver, making Colorado the site for trial.

“Mr. Rudolph was first ‘arrested” for Foreign Murder — or restrained of his liberty in connection with that charge — in Denver,” wrote Chief Judge Jerome A. Holmes in the Sept. 8 opinion.

There were no witnesses to what happened on Oct. 11, 2016, when Rudolph and his wife, Bianca, were preparing to leave the Zambian camp where the couple had traveled to hunt animals. Bianca sustained a fatal shotgun wound in their cabin and the question became whether her death was accidental or homicide.

Rudolph was a wealthy Pittsburgh dentist and both spouses had cheated on each other during their marriage. At the time of Bianca’s death, Rudolph was having an affair with Milliron, who was an administrator at Rudolph’s dental practice.

The prosecution presented circumstantial evidence that Rudolph was unbothered by, and even benefitted from, his wife’s death. He received more than $4.8 million from her life insurance policies, he spent millions of dollars on properties and cars, and he appeared fixated on quickly cremating her remains in Africa.

In early 2020, a bartender at a steakhouse in Arizona overheard Rudolph allegedly tell Milliron, “I killed my f—ing wife for you.” The defense later argued Rudolph had actually said, “They are saying I killed my f—ing wife for you,” but the prosecution maintained Rudolph would not have known about any investigation until much later.

The government ultimately wanted to prosecute Rudolph in Denver, where the primary case agent was. Law enforcement waited until Rudolph left for Mexico in late 2021, then arranged for him to be detained and returned to Denver.

A grand jury indicted Rudolph in early 2022 for foreign murder and mail fraud. The latter charge related to Rudolph defrauding Bianca’s insurance companies by representing her death as an accident. A grand jury also indicted Milliron for perjury, being an accessory to homicide and obstructing a grand jury proceeding.

After a joint trial, jurors convicted Rudolph, resulting in a life sentence in prison. They also convicted Milliron on four of seven counts. Her appeal is proceeding separately.

To the 10th Circuit, Rudolph argued U.S. District Court Senior Judge Wiliam J. Martínez incorrectly refused to separate the trials. Milliron, were she not also a defendant, could have allegedly testified that the bartender’s recollection of the steakhouse conversation was inaccurate. Moreover, other damaging testimony related to Milliron would not have come in.

Martínez had denied the request based on the fact that Milliron “does not definitively state that she would testify at Defendant Rudolph’s trial; instead, she only states that she ‘would be able to testify at’ his trial.”

“There’s some condition in terms of how she’s understanding when she would be available, when she can testify,” observed Judge Veronica S. Rossman during oral arguments to the 10th Circuit.

Rudolph also challenged the location of his trial in Colorado. Federal law indicates offenses that happen outside the U.S. must be tried in the place where the defendant is “arrested” or is “first brought.” To Rudolph, the place he was arrested was in Mexico in 2021, and the place he was first brought after Bianca’s killing was Atlanta in 2016.

The 10th Circuit panel disagreed with Rudolph. On the issue of the combined trial, Holmes agreed with Martínez that Milliron never committed categorically to testifying for Rudolph in a separate trial. Moreover, a jury may have viewed her version of the steakhouse conversation with “a healthy dose of skepticism” given the luxurious lifestyle she enjoyed from her relationship with Rudolph.

“Furthermore, if Ms. Milliron had been tried first and convicted — as she ultimately was on four of the seven counts in the joint trial — her prior convictions would have been admissible in Mr. Rudolph’s trial for impeachment purposes. Those convictions would have considerably damaged Ms. Milliron’s credibility in the eyes of a reasonable jury,” wrote Holmes.

Holmes continued that Rudolph was, in fact, “arrested” in Denver because he was not charged with foreign murder until he was on the plane from Mexico. Moreover, the law did not designate the place he was “first brought” as the first place of arrival after an offense. But rather, it is the place a defendant is first brought “in custody” — also Denver, Holmes explained.

The panel further concluded Martínez properly admitted certain challenged evidence and that he committed no error by requiring Rudolph to forfeit the assets he purchased after receiving Bianca’s life insurance payout.

The case is United States v. Rudolph.