United States v. Spencer, No. 13-3004 (8th Cir. 2014)
Annotate this CaseDefendant appealed his conviction for being a felon in possession of a firearm. Defendant challenged the district court's denial of his motion for a new trial based on the government's failure to disclose exculpatory evidence and its misstatements during closing arguments. The court concluded that much of the alleged inconsistency between the arresting officer's police report and his testimony at trial is semantic; likewise, the officers' mishandling of the sock does not negate their testimony that they had observed defendant carrying the sock; defendant failed to prove that the government's delay in disclosing the information at issue deprived that information of its usefulness and that this deprivation materially affected the outcome of his trial; the evidence of defendant's guilt was overwhelming and the probative value of his proffered evidence is minimal; and, therefore, the district court did not abuse its discretion in denying a new trial under Brady v. Maryland. Finally, the district court did not abuse its discretion in refusing to grant a new trial based on a prosecutor's remarks which could be construed as improper where they did not prejudice defendant.
Court Description: Criminal Case - new trial motion. District court did not abuse its discretion in denying motion for new trial under Brady v. Maryland for government's failure to disclose that officer would testify in a way that was inconsistent with police report and for mishandling of evidence that prevented a DNA analysis. Probative value of any inconsistency was minimal and use of impeachment evidence would not have led jury to acquit Spencer in light of overwhelming evidence of guilt. Prosecutor's comments at closing argument, to the extent they could be construed as improper, would not have affected jury's verdict and thus district court did not abuse its discretion in denying motion for new trial based on prosecutorial misconduct. [ May 20, 2014
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