United States v. Casteel, No. 11-3717 (8th Cir. 2013)
Annotate this CaseDefendant appealed his convictions for (1) carjacking, using or carrying a firearm in relation to a violent crime, obstructing justice, and witness tampering, in his first trial; and (2) two counts of being a felon in possession of a firearm in the second trial. The court concluded that, even if the court assumed that the district court had the authority to grant defendant a retroactive competency determination more than a year after judgment, defendant failed to persuade the court that the district court committed reversible error in denying his requested relief; the district court did not err in finding defendant competent to stand trial and to proceed with sentencing; a jury reasonably found defendant possessed the firearms as required for conviction under 18 U.S.C. 922(g); the district court properly denied defendant's motion to suppress where there was probable cause to search for evidence of the robbery; defendant did not suffer any harm as a result of alleged sentencing errors; and defendant's remaining challenges to the sufficiency of the evidence of carjacking and the admission of evidence related to the July 27, 2008 burglary were foreclosed by the court's rejection of identical claims in defendant's son's direct appeal. Accordingly, the court affirmed the convictions and sentence.
Court Description: Criminal case - Criminal law and sentencing. For the court's prior opinion in the matter, see U.S. v. Casteel, 663 F.3d 1013 (8th Cir. 2011). Even if the court assumes the district court had authority to grant defendant a retroactive competency determination more than a year after judgment, defendant failed to establish that the court erred in denying his request for such a determination; the district court did not err in finding defendant competent to stand trial on firearms charges or in finding that he was competent to proceed with sentencing; the evidence was sufficient to support defendant's conviction for being a felon in possession of a firearm; when police searched defendant's auto incident to his arrest, they had reason to believe the car contained additional evidence of criminal activity, and the district court did not err in admitting the evidence seized from the car; any error in sentencing was harmless.
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