Tiger King Loses Appeal to Undo Murder-for-Hire Convictions

Joseph Maldonado—also known as Joe Exotic from the Netflix series “Tiger King"—lost his appeal for a new trial on murder-for-hire and Endangered Species Act charges after the Tenth Circuit said his arguments were either waived or without merit.

Maldonado claimed the district court applied the wrong standard when it denied his motion for a new trial based on newly discovered evidence, which included evidence of allegedly recanted witness testimony. But he’d urged the district court to use the very same standard he now challenged, so the argument was waived as invited error, the US Court of Appeals for the Tenth Circuit said.

Although the district court didn’t hold an evidentiary hearing to suss out Maldonado’s claims about witnesses lying or recanting their statements, it was within the judge’s discretion to refuse to do so, the appeals court said Wednesday.

The US Court of Appeals for the Tenth Circuit generally affirms the refusal to hold an evidentiary hearing when a trial court has already had several opportunities to assess witness testimony.

This appeal was Maldonado’s fourth trip to the Tenth Circuit. In an earlier appeal, he argued successfully to have his 264-month prison sentence reduced to 252 months.

Maldonado also challenged his convictions for taking and killing five tigers in violation of the Endangered Species Act, claiming newly discovered evidence showed he only killed the tigers because they were sick.

According to Maldonado, he was providing “healthcare.” But his own testimony established he shot and killed the tigers solely because it was cheaper and faster than having a veterinarian administer euthanasia, the appeals court said. Plus, he could have discovered what he claimed was new evidence before the first trial.

The appeals court rejected his remaining arguments, including that the government should have been required to perform an autopsy on the tigers’ bodies.

Even if recovery of the tigers’ bodies would prove they were sick, Maldonado failed to show how that might have altered the outcome of the case, the court said.

Judge Allison H. Eid authored the unpublished decision, joined by Timothy M. Tymkovich and Bobby R. Baldock.

Maldonado is represented by Roger Roots of Washington, DC.

The case is United States v. Maldonado, 10th Cir., No. 23-06207, unpublished 7/9/25.