United States v. Reave, No. 10-3145 (8th Cir. 2011)
Annotate this CaseDefendant was convicted of interfering with interstate commerce by robbing an armored car and using, carrying, brandishing, and discharging a firearm during and in relation to that robbery. Defendant appealed his convictions on several grounds. The court held that even if the court erred by barring defendant's attempt to impeach a certain witness's testimony by cross-examining her about her alleged involvement in a 2007 fraudulent insurance claim for vandalism, any such error did not affect defendant's substantial rights where such an inquiry would have impeached defendant's testimony because he was likewise involved in the alleged fraud. The court also held that, even if defendant's testimony had been totally undermined, the other evidence linking defendant to the robbery was overwhelming. The court further held that the district court did not err, let alone abuse its discretion, in denying defendant's motion for a new trial under Brady because the phone records at issue were not material; the evidence was sufficient to submit the instruction, regarding defendant's attempt to influence the witness, to the jury; and the evidence was sufficient to support defendant's convictions and a reasonable jury could have found defendant guilty beyond a reasonable doubt. The court declined to address defendant's claims of ineffective assistance of counsel. Accordingly, the court affirmed the convictions.
Court Description: Criminal case - Criminal law. Even if the district court erred in limiting the cross-examination of the government's witness, the error was harmless because evidence of the witness's dishonesty was already before the jury, the line of inquiry would also have impeached defendant and the evidence of his guilt was overwhelming; Brady challenge rejected as the evidence in question was not material; no error in giving instruction concerning defendant's attempt to influence a witness's testimony; evidence was sufficient to support defendant's conviction for robbing an armored car; claim of ineffective assistance of counsel would not be considered on direct appeal.
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