United States v. Washburn, No. 12-3080 (8th Cir. 2013)
Annotate this CaseDefendant was convicted of wire fraud, money laundering, and making false statements to the United States Probation Office. On appeal, defendant argued that the district court erred at trial in admitting certain evidence and that he was denied his right to "conflict-free" counsel and a fair trial. The court concluded, inter alia, that defendant's plea-statement waiver was knowing and voluntary and thus the district court did not err in allowing the government to successfully offer the plea agreement factual stipulation as evidence against defendant; the court affirmed the district court's admission of the factual stipulation under Federal Rule of Evidence 403; the court affirmed the denial of defendant's motion to sever because the district court did not abuse its discretion in its determination that defendant's prior conviction for wire fraud and money laundering would be admissible on all charges and would not be unduly prejudicial; the court dismissed plaintiff's Sixth Amendment challenge without prejudice because the record was not fully developed enough to hold that a plain miscarriage of justice occurred; and the court affirmed the district court's decision to continue with trial despite defendant's brief absence.
Court Description: Criminal case - Criminal law and sentencing. The district court did not err under Rule 410 in admitting defendant's plea agreement stipulation of facts as the plea agreement specifically stated the stipulation could be admitted if defendant violated the plea agreement and this was a knowing and voluntary waiver of his rights; nor did the court err under Rule 403, as defendant failed to show how he was prejudiced by admission of the stipulation and never requested any limiting instruction or made any objection to the instructions relevant to this claim; no error in denying defendant's motion to sever the financial counts from charges related to making false statements to the Probation Office; defendant failed to demonstrate that his trial counsel had a conflict of interest; court would not consider the claim as an ineffective assistance of counsel claim as it was not fully developed enough to permit review; district court did not err in finding defendant voluntarily absented himself from court on the day of closing arguments and did not err in continuing the trial without him.
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