United States v. Eldridge, No. 18-3294 (2d Cir. 2021)
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The Second Circuit affirmed Defendants Eldridge and Allen's convictions and sentences for offenses arising from their participation in a drug-dealing enterprise that operated in Buffalo, New York, from 2003 to 2005.
The court concluded that the district court’s decision to install a waist-high black curtain around the defense tables before trial did not violate defendants' rights to a fair trial. The court further held that, although United States v. Davis, 139 S. Ct. 2319 (2019), and United States v. Barrett, 937 F.3d 126 (2d Cir. 2019), have invalidated at least one of the three theories upon which Eldridge's second 18 U.S.C. 924(c) conviction might have been premised, Eldridge has failed to show that any error affected his substantial rights in light of the evidence supporting the third, valid theory—namely, that Eldridge participated in an attempted Hobbs Act robbery. In reaching this conclusion, the court held that even in cases where an unpreserved claim of error is based on a supervening change in case law, the defendant bears the burden of establishing all four prongs of the plain-error standard. Finally, the court held that Section 403(a) does not apply to Eldridge because the district court imposed his sentence before Congress passed the First Step Act, and that the pendency of his direct appeal does not change that fact. The court affirmed defendants' remaining claims in a separate summary order.
The court issued a subsequent related opinion or order on March 30, 2023.
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