United States v. Davis, No. 16-3361 (8th Cir. 2017)Annotate this Case
The Eighth Circuit affirmed defendant's convictions for three crimes related to the manufacture of methamphetamine. Even assuming that the district court improperly excluded defendant's proposed post-indictment prescription evidence for pseudoephedrine and she adequately preserved and presented her constitutional argument to the district court, the Eighth Circuit held that the exclusion of that evidence did not affect her substantial rights or materially influence the verdict. In this case, evidence of defendant's guilt was overwhelming. The court explained that, though largely contradicted by the balance of the medical evidence, defendant was still able to present her defense that she legitimately bought use quantities of pseudoephedrine to self-treat her COPD during the time at issue. Furthermore, the exclusion of that evidence did not deprive her of a meaningful opportunity to present a complete defense.