United States v. Jackson, No. 16-2433 (8th Cir. 2017)
Annotate this CaseDefendant was sentenced to 480 months in prison after he was convicted of second degree murder and assault with a deadly weapon. The court concluded that the district court did not clearly err in crediting a law enforcement officer's testimony that defendant volunteered information regarding his drug use and lack of sleep; evidence regarding defendant's physical and mental health was properly admitted; and, although it was error to admit defendant's response to the officer's question regarding the last time he cut his hair, the admission was harmless. The court also concluded that the district court did not abuse its discretion by admitting evidence of the victim's prior acts of violence; the district court did not err in denying defendant a surrebuttal closing argument; the district court did not err in considering and explicitly rejecting defendant's request for a variance under USSG 5K2.10, 5K2.10, and under the forthcoming 2016 Sentencing Guidelines; and the district court did not err by denying defendant's motion for a continuance in order for him to obtain a mental health evaluation. Accordingly, the court affirmed the judgment.
Court Description: Kelly, Author, with Murphy, Circuit Judge, and Montgomery, District Judge] Criminal case - Criminal law and sentencing. Argument that defendant's in-custody statements should be suppressed because of his drug use and lack of sleep rejected because an officer credibly testified that defendant volunteered certain statements and that they were not made in response to any questions by law enforcement; defendant's responses to limited questions about his current mental and physical state were admissible; response to a question regarding the last time defendant had his hair cut was not admissible as it was asked with the intention of obtaining an incriminating response; however the error in admitting the response was harmless as it was unlikely that this single statement had a major impact on the jury's decision; the district court did not err in refusing to admit four of the eight instances of the victim's prior acts of violence as there was no evidence that the victim had committed two of the acts, evidence concerning one of the acts was cumulative, and one of the incidents, dating back to when the victim and defendant were about 15, was lacking in probative value; constitutional challenge to Rule 29.1 regarding the order of closing argument rejected; the district court did not abuse its discretion by denying defendant's request for sur-rebuttal concerning his claim of self-defense; the district court considered and explicitly rejected defendant's request for a variance under Guidelines Sec. 5K2.10 and defendant's claim that the court erred by failing to consider the request must be rejected; district court did not err in refusing to grant such a variance; the district court did not err in refusing to sua sponte consider a variance based on a proposed amendment to the Guidelines where the amendment would have no effect on the range; no error in denying request to postpone sentencing for a mental health exam as defendant had one in 2010 and there was no reason to believe another exam would produce different results or cause the court to impose a lesser sentence.
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.