United States v. Melton, No. 16-3103 (8th Cir. 2017)
Annotate this CaseThe Eighth Circuit affirmed defendant's conviction and sentence for twelve counts of mail fraud and five counts of failure to pay employment taxes. The court rejected defendant's evidentiary challenges; denied exercising its discretion to recognize any plain error in the prosecution's comments attacking defendant's testimony during closing remarks; denied defendants motion for acquittal because his unauthorized actions demonstrated a pattern designed to conceal his use of company funds to pay his personal debt; and held that the cumulative effect of any errors here did not substantially affect defendant's right to a fair trial. The court also held that the district court did not commit procedural errors by applying offense enhancements based on the use of sophisticated means under USSG 2B1.1(b)(10)(C); the endangerment of financial security under USSG 2B1.1(b)(16)(B)(ii)(I); and the obstruction of justice under USSG 3C1.1.
Court Description: Riley, Author, with Gruender, Circuit Judge, and Schreier, District Judge] Criminal case - Criminal law and sentencing. No error in admitting minutes of board meetings which contained statements that defendant had committed criminal violations when defendant failed to take advantage of the government's offer to redact the minutes and the court gave a limiting instruction; admission of certain emails may have been error, but the error was harmless as the emails were inconsequential in the overall trial and did not affect the verdict; any error in admitting an audit report was harmless because the report was cumulative to the testimony at trial; government's comments in closing argument attacked defendant's trial testimony, which is a fair topic for closing remarks, and any error in the government's comments was not likely to have affected the jury's verdict in light of the overwhelming evidence of defendant's guilt; the evidence was sufficient to support defendant's conviction on mail fraud charges; cumulative impact of trial errors did not substantially affect defendant's right to a fair trial; no error in imposing sentencing enhancements for sophisticated means,endangerment of defendant's employer's financial security, and obstruction of justice.
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