United States v. Maybee, No. 11-3254 (8th Cir. 2012)
Annotate this CaseAfter a jury trial, Defendant was convicted on six counts related to willfully causing bodily injury to another because of that person's race, color, or national origin in violation of certain provisions of the Shepard-Byrd Hate Crimes Prevention Act. The district court sentenced Defendant to 135 months' imprisonment. The Eighth Circuit Court of Appeals affirmed Defendant's convictions and sentence, holding (1) 18 U.S.C. 249(a)(1) was constitutional; (2) the evidence was sufficient to sustain the conviction; (3) the district court did not abuse its discretion in refusing to grant Defendant's motion for a new trial; and (4) the district court did not err in failing to sua sponte grant Defendant a minor role adjustment.
Court Description: Criminal case - Criminal law and sentencing. Challenge to the constitutionality of 18 U.S.C. Sec. 249(a)(1) rejected; evidence was sufficient to support defendant's conviction for violating the Shephard- Byrd Hate Crimes Act; district court did not abuse its discretion in denying motion for new trial; issues raised for the first time on appeal would not be considered; district court did not err in denying defendant's request for a minor role adjustment under Guidelines Sec. 3B1.2(b) in light of the evidence showing he played a central role in every aspect of the crimes.
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