United States v. Ranson Long Pumpkin, No. 20-2743 (8th Cir. 2022)
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Defendants were convicted of committing a carjacking resulting in serious bodily injury. Under a separate count, they were convicted of using and discharging a firearm during and in relation to a crime of violence, the carjacking. Defendants appealed certain evidentiary and jury instruction issues, and also challenged the sufficiency of the evidence supporting the discharging a firearm conviction.
The Eighth Circuit affirmed Defendant's convictions for carjacking resulting in serious bodily injury, finding no error in the district court's evidentiary rulings and jury instructions. However, the court concluded that Defendant's discharging a firearm conviction must be reduced to using a firearm. The court explained that the carjacking offense was complete at the moment of the taking, so the fact that the firearm was used after that point could not be used to support the discharging a firearm offenses.
Court Description: [Colloton, Author, with Shepherd and Kelly, Circuit Judges] Criminal case - Criminal law. The district court did not violate defendants' Sixth Amendment rights by not permitting them to cross-examine two government witnesses regarding their drug use after it determined they would likely invoke the Fifth Amendment during their cross-examination; the evidence was sufficient to support defendants' convictions for carjacking resulting in serious bodily injury; there was no error in giving an instruction of aiding and abetting the use and discharge of a firearm in relation to a crime of violence; while the evidence in the case supports the defendants' conviction for the basic Sec. 924(c) offense of using a firearm, the evidence fell short of establishing that they discharged a firearm in relationship to the carjacking as the offense was necessarily ended before the firearms were discharged; as a result their conviction for the greater offense of discharging a firearm under Sec. 924(C)(1)(A)(iii) must be vacated and reduced to convictions for using a firearm under Sec. 924(c)(1)(a)(i). Judge Kelly, dissenting.
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