United States v. Lewis, No. 19-2549 (8th Cir. 2020)
Annotate this CaseThe Eighth Circuit affirmed defendant's conviction and sentence for conspiracy to distribute a controlled substance. The court held that the evidence was sufficient to support defendant's conviction; the district court did not abuse its discretion by denying defendant's motion for a new trial based on newly discovered evidence where the evidence was only impeachment evidence and not material, it is not probable that the newly discovered evidence would produce an acquittal at a new trial, and the evidence did not show that the government's witnesses perjured themselves; the district court did not clearly err in determining the drug quantity attributed to defendant; the district court did not abuse its discretion by applying a three-level manager or supervisor role enhancement under USSG 3B1.1(b) and a two-level enhancement for obstruction of justice under USSG 2D1.1(b)(16)(D); and the district court did not abuse its discretion in determining defendant's sentence by accepting the 10-to-1 pure meth mixture and pure meth mixture guidelines range.
Court Description: [Benton, Author, with Smith, Chief Judge, and Kobes, Circuit Judges] Criminal case - Criminal law and sentencing. The evidence was sufficient to support defendant's conviction for conspiracy to distribute methamphetamine;the district court did not err in denying defendant's motion for new trial based on newly discovered evidence as the evidence was only impeachment evidence and was not material; nor was it probable that the newly discovered evidence would have produced an acquittal; finally, the district court did not err in determining the newly discovered evidence did not show the government's witnesses perjured themselves; the district court did not err in determining the amount of meth to be attributed to defendant as the meth shipments received by other co-conspirators were part of the same course of conduct as the conspiracy, were reasonably foreseeable and were in furtherance of the conspiracy; no error in applying a three-level manager or supervisor role enhancement under Guidelines Sec. 3B1.1 cmt. n.4; no error in applying a two-level enhancement for obstruction of justice under Guidelines Sec. 2D1.1(b)(16)(D); the district court considered defendant's policy-based argument against the 10-to-1 pure meth/meth mixture guideline and was within its discretion in determining what weight to give the argument in setting defendant's sentence.
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