United States v. Ross, No. 18-2800 (8th Cir. 2020)
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The Eighth Circuit affirmed Defendants Ross and King's convictions and sentences for multiple federal charges arising from the carjacking, kidnapping, and murder of Jaime Patton. Jaime was abducted in his Jeep Patriot while leaving the hospital to buy his pregnant wife, who was about to give birth to their second child, a muffin and milk from a convenience store.
The court held that the evidence was sufficient to support defendants' conviction for using a firearm in furtherance of kidnapping and carjacking that resulted in felony murder; a violation of 18 U.S.C. 2119 constitutes a "crime of violence" under section 924(c), and defendants were properly convicted under section 924(j) of causing death through use of a firearm in the course of a carjacking; the evidence was sufficient to support Ross's convictions for kidnapping, for carjacking resulting in death, for using a firearm in furtherance of a carjacking resulting in felony murder, and for being a felon in possession of a firearm; the district court did not abuse its discretion in admitting a text message between the defendants; the district court did not abuse its discretion by refusing to give defendants' requested jury instructions; defendants' combined mandatory minimum sentences on counts two, three, and five did not violate the Eighth Amendment; and King's sentence is not substantively unreasonable.
Court Description: [Colloton, Author, with Smith, Chief Judge, and Stras, Circuit Judge] Criminal case - Criminal law and sentencing. The evidence was sufficient to support defendants' convictions for carjacking and kidnapping that ended in felony murder - a violation of U.S.C. Sec. 2119 constitutes a crime of violence under 18 U.S.C. Sec. 924(c), and the defendants were properly convicted under Sec. 924(j) of causing death through use of a firearm in the course of carjacking; evidence was sufficient to support defendant Ross's conviction for kidnapping, for carjacking resulting in death, for using a firearm in furtherance of a carjacking resulting in felony murder, and for being a felon in possession of a firearm; no error in admitting a text between defendants suggesting they commit a robbery as it proves an agreement to commit the charged offenses; no error in refusing to give defendant Ross's proposed instruction on eyewitness testimony or defendant King's proposed instruction on the defense of duress; the requirement of 18 U.S.C. Sec. 924(c)(1)(D) that a life sentence for using a firearm must run consecutive to mandatory life terms for other offenses in not an Eighth Amendment violation; defendant King's argument that his sentence is substantively unreasonable because he was less culpable than defendant Ross rejected. Judge Stras, concurring in the judgment and dissenting in part.
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