United States v. Delgrosso, No. 16-1980 (8th Cir. 2017)
Annotate this CaseDefendants Delgrosso and Cain were convicted of conspiracy to distribute methamphetamine, money laundering, and conspiracy to commit money laundering. Delgrosso also was found guilty of failing to file IRS Form 8300. The court concluded that the district court did not abuse its discretion in denying defendants' motions for a new trial based on Jerry Wright's post-trial affidavit because, even if Wright testified or the affidavit were admitted, the Government could impeach Wright's credibility by introducing evidence of his seven prior felony convictions. Furthermore, even if the jury believed Wright's statements, that does not mean that it would likely acquit defendants. In this case, the Government provided ample evidence that would allow the jury to conclude that Delgrosso and Cain knew or willfully blinded themselves to the fact that Wright acquired his cash through drug sales. The court also concluded that the district court did not abuse its discretion in denying Delgrosso's motion for a new trial based on Government misconduct under Brady v. Maryland where it was untimely and, even if it was timely, his allegations either relate to issues that were irrelevant or were directly contradicted; the district court did not plainly err by instructing the jury on willful blindness; the district court did not err in denying Delgrosso's motion for acquittal where sufficient evidence supported the jury's verdict; and the district court did not clearly err in denying Delgrosso safety-valve relief. Accordingly, the court affirmed the judgment.
Court Description: Gruender, Author, with Smith, Chief Judge, and Benton, Circuit Judge] Criminal case - Criminal law and sentencing. The district court did not err in denying defendants' motions for new trial based on newly-discovered evidence as the affidavit defendants rely on would have been inadmissible and had affiant testified, he would have been subject to impeachment based on his seven felony convictions; further, the evidence, even if believed, was not likely to lead to an acquittal; the motion for new trial raising a possible issue of government misconduct in connection with a Brady claim was untimely; even if it had been timely, the material was irrelevant or contradicted by strong evidence and it was not error to deny the request for new trial; no error in giving a willful blindness instruction on the facts present in the case; the evidence was sufficient to support defendant Delgrasso's convictions on drug conspiracy and money laundering conspiracy charges; no error in denying Delgrasso's request for safety-valve sentencing as he had not truthfully provided all information concerning the offenses.
Some case metadata and case summaries were written with the help of AI, which can produce inaccuracies. You should read the full case before relying on it for legal research purposes.
This site is protected by reCAPTCHA and the Google Privacy Policy and Terms of Service apply.