United States v. Huggans, No. 09-3441 (8th Cir. 2011)
Annotate this CaseDefendant was convicted of conspiracy to distribute cocaine and attempt to posses with intent to distribute cocaine, and was sentenced to life imprisonment. Defendant appealed both his convictions and his sentence. The court held that the district court did not err in denying defendant's motion to dismiss the indictment for insufficient evidence where information in the indictment provided defendant with fair notice of the charges against him. The court also held that the district court did not err in denying defendant's motions for a bill of particulars where the government's disclosures were more than sufficient to enable him to understand the nature of the charges, prepare a defense, and avoid unfair surprise. Moreover, defendant failed to describe any instance in which he was actually surprised at trial or any actual prejudice from the denial of his motions. The court affirmed the district court's denial of defendant's motion to sever two counts where there was no actual prejudice nor any abuse of discretion. The court further held that there was sufficient evidence to connect defendant to the conspiracy and to prove that he took a substantial step towards acquiring 20 kilos of cocaine. The court finally held that the district court did not err in finding that defendant could not challenge his prior convictions; the district court did not abuse its discretion in denying defendant's motion for a new trial based on newly discovered evidence; and the district court did not err in failing to conduct an in camera review of the PSRs of cooperating government witnesses because neither party suggested such review.
Court Description: Criminal Case - conviction and sentence. District court did not err in denying motion to dismiss indictment for insufficiency, as the indictment stated the time frame for the conspiracy and the drugs involved and the attempt charge need not specify the substantial step committed in furtherance of the offense. The district court did not abuse its discretion in denying bill of particulars in light of disclosure by government of discovery and failure by Huggans to show actual surprise. District court did not abuse its discretion in denying motion to sever the two counts as there was no actual prejudice. Sufficient evidence was presented connecting Huggans to the conspiracy and proving Huggans took a substantial step towards acquiring 20 kilograms of cocaine. District court did not err in refusing to equitably toll the five-year limitations period for challenging his prior conviction. Denial of motion for new trial based on newly discovered evidence was not a clear abuse of discretion, as evidence is not newly discovered, and would not warrant a new trial. District court did not abuse its discretion in failing to conduct in camera review of PSRs of cooperating government witnesses because neither party requested such review.
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