United States v. Davis, No. 16-3361 (8th Cir. 2017)
Annotate this CaseThe 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.
Court Description: Rossiter, Author, with Riley and Beam, Circuit Judges] Criminal case - Criminal law. The evidence of defendant's guilt regarding the illegal procurement of pseudoephedrine was overwhelming and any error in refusing to admit marginally relevant evidence that defendant obtained a post-conspiracy prescription for pseudoephedrine was harmless; while largely contradicted by the balance of the medical evidence, defendant was still able to present her defense that she legitimately bought the drug to self treat her COPD during the time at issue, and the exclusion of the post-indictment prescription evidence did not deprive her of a meaningful opportunity to present a complete defense. [ June 13, 2017
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