United States v. Wyatt, No. 18-1135 (10th Cir. 2020)
Annotate this CaseDefendant Richard Wyatt challenged two convictions for conspiring with others to deal in firearms without a federal firearms license. The Government conceded that the district court erred in failing to instruct the jury that, in order to convict Wyatt of these conspiracy offenses, the jury had to find that Wyatt and his alleged co-conspirators acted willfully -- that they knew they were agreeing to do something unlawful. The Government further conceded that this error warranted vacating Wyatt’s conspiracy convictions and remanding for a new trial. But Wyatt contended that there was insufficient evidence presented at trial for a reasonable jury to find that he and his co-conspirators acted willfully and, therefore, the Tenth Circuit court should instead, dismiss the conspiracy counts charged against him with prejudice. The Tenth Circuit declined to dismiss, concluding there was sufficient evidence presented at trial that, if believed, would have supported a reasonable jury finding beyond a reasonable doubt that Wyatt and his co-conspirators knew they were agreeing to violate the law. Wyatt’s two conspiracy convictions were vacated and the matter remanded to the district court for further proceedings.
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