United States v. Washington, No. 10-7013 (10th Cir. 2011)
Annotate this CaseAfter a jury trial, Defendant Deandre Washington was convicted for witness tampering and sentenced to 360 months in prison. The conviction stemmed from Defendant's alleged part in a murder-for-hire scheme designed to kill a local law enforcement officer before the officer testified against him at trial. Defendant raised multiple issues to appeal his conviction. Principally, Defendant argued that the evidence against him was insufficient to support his conviction and that the district court abused its discretion by excluding testimony of a defense witness who was presented in the courtroom during trial in violation of the Rule of Sequestration. Upon review of the trial record, the Tenth Circuit concluded that the evidence presented at trial was sufficient to support Defendant's conviction. Furthermore, the Court concluded that given the strong evidence of guilt that existed at the time of trial and the inconsistencies in the witness' testimony that had otherwise been highlighted by the government, the district court's error in allowing the witness to be present at a time of sequestration was harmless. The Court affirmed Defendant's conviction.
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