United States v. Denton, No. 18-4404 (4th Cir. 2019)
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The Fourth Circuit affirmed defendant's conviction for conspiring to distribute fifty grams or more of a mixture or substance containing methamphetamine, holding that the evidence was sufficient to establish that defendant conspired to distribute the threshold drug quantity of fifty grams of methamphetamine.
The court also held that, although the district court's jury instructions on the drug conspiracy offense constituted plain error, the error did not seriously affect the fairness, integrity, or public reputation of the judicial proceedings. Finally, the court held that defendant's Sixth Amendment confrontation rights were not violated by the admission of business record certifications from Facebook, Google, and Time Warner Cable; the district court did not err by admitting the bad acts evidence relating to his prior threats and assaults; and defendant's remaining contentions of error were rejected.
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