United States v. Cowden, No. 17-4046 (4th Cir. 2018)
Annotate this CaseThe Fourth Circuit affirmed defendant's conviction of deprivation of rights under color of law in violation of 18 U.S.C. 242. In this case, the evidence showed that defendant, in the course of his police duties, assaulted another individual following his arrest on various charges. The court held that the district court did not abuse its discretion by admitting evidence of prior bad acts; the evidence was more than sufficient to support the jury's determination that defendant acted willfully, as required under section 242; the district court did not abuse its discretion in using a special verdict form and by refusing defendant's proposed jury instruction on lesser-included offenses; and the district court acted within its discretion in requiring defendant to pay the full amount of the victim's medical expenses.
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