United States v. Johnson, No. 16-3483 (8th Cir. 2017)
Annotate this CaseThe Eighth Circuit affirmed defendant's conviction and 30 year sentence for physically assaulting and raping his estranged wife. The court held that the district court did not abuse its discretion by admitting a social worker's expert testimony under FRE 702 without a Daubert hearing where her testimony rested on a reliable foundation and by refusing to exclude the testimony under Rule 403. The court also held that the district court did not abuse its discretion by admitting testimony regarding his prior tribal court convictions, prior bad acts, and the victim's statement. Finally, the court held that the district court did not err by applying a two level enhancement for obstruction of justice under USSG 3C1.1 and a two level vulnerable victim enhancement under USSG 3A1.1(b)(1).
Court Description: Shepherd, Author, with Wollman and Colloton, Circuit Judges] Criminal case - Criminal law and sentencing. The district court did not err in admitting testimony from a licensed social worker on domestic violence models without a Duabert hearing as her testimony rested on a reliable foundation; the testimony was admissible under Rule 702 based on the district court's determination that the information would be helpful to the jury in understanding the evidence; further, the testimony did not mislead the jury, confuse the issues or otherwise unfairly prejudice defendant, and it was properly admitted under Rule 403; no error in admitting the victim's testimony concerning defendant's prior tribal court convictions involving assaults against her; the evidence was material as to intent and was similar in kind to the crimes charged; further, the victim's testimony by itself was sufficient to support a finding that defendant committed the conduct underlying his prior convictions; nor was the evidence introduced solely to show defendant's propensity to commit crimes; evidence that the victim had previously assaulted defendant was properly excluded under Rule 404(b); any error in admitting a written statement the victim gave police after she escaped from defendant was harmless; no error in imposing sentencing enhancements for obstruction of justice based on defendant's threat during the incident that he would kill the victim if she sought to contact the police or get help, as there is no authority which limits the obstruction-of-justice enhancement to conduct occurring after the completed offense, and defendant's threats were precisely what the Guidelines contemplate as an attempt to prevent the victim from reporting the crime; no error in imposing a vulnerable victim enhancement.
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