United States v. Reed, No. 19-2487 (8th Cir. 2020)
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The Eighth Circuit affirmed defendant's conviction for three counts of drug and gun charges. The court held that the evidence was sufficient to convict defendant for conspiracy to distribute heroin, powder cocaine, and crack cocaine, as well as for possessing firearms as a convicted felon. The court also held that the district court did not err by denying defendant's motion for a new trial based on defendant's claim that the jury was not representative of a cross-section of the community where defendant failed to provide evidence of the racial composition of the jury pool used by the District of Minnesota, or even the composition of the potential jurors called for his trial.
Finally, the court upheld defendant's within-Guidelines 240 month sentence, holding that the district court expressly recognized its authority to vary based on a disagreement with the crack cocaine conversion rate but declined to do so. The court stated that the district court did not abuse its discretion by declining to vary downward and that defendant's sentence was substantively reasonable.
Court Description: [Kelly, Author, with Erickson and Stras, Circuit Judges] Criminal case - Criminal law and sentencing. Evidence was sufficient to support defendant's convictions for conspiracy to distribute cocaine and crack, possession of heroin and crack with intent to distribute, and being a felon in possession of a firearm; defendant's claim the jury was not representative of a cross-section of the community rejected as defendant did not provide evidence of the racial composition of the jury pool used by the District of Minnesota or even the composition of the potential jurors called for his trial; the district court recognized its authority to vary based on a policy disagreement with the crack cocaine conversion rate, and it did not abuse its discretion by declining to vary downward; defendant's within-Guidelines sentence was substantively reasonable.
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