United States v. Keys, No. 12-3259 (8th Cir. 2013)
Annotate this CaseDefendant appealed his conviction by a jury of conspiracy to distribute 280 grams or more of crack cocaine. The court affirmed, concluding that the district court did not abuse its discretion in denying the request for a Franks hearing and denying the motion to suppress where defendant could not show that the alleged false arrest was necessary to the finding of probable cause; evidence was sufficient for the district court to deny defendant's Rule 29 motion for judgment of acquittal; and the court rejected defendant's Brady claim where plaintiff failed to show that earlier disclosure of the substance of the "new" testimony at issue would have altered the result of the proceeding.
Court Description: Criminal case - Criminal law. No error in denying a Franks hearing as defendant could not show that the allegedly false statement in the search warrant application was necessary to a finding of probable cause; evidence was sufficient to support defendant's conviction for conspiracy to distribute crack; Brady claim rejected.
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