United States v. Williams, No. 10-1298 (8th Cir. 2011)
Annotate this CaseDefendant was convicted of possessing crack cocaine with the intent to distribute, of conspiring to do the same thing, and of conspiring in crack cocaine distribution. At issue was whether the district court properly granted defendant's post-verdict motion judgment of acquittal and alternatively, for a new trial. The court held that the balance of evidence favored the government, not defendant, where the evidence was sufficient to support the jury's finding that defendant engaged in a conspiracy to distribute crack. Therefore, the motion to acquit should have been denied. The court held, however, that it was not a clear and manifest abuse of discretion for the district court to grant defendant a new trial in light of the district court's opinion after observing the trial that Federal Rule of Evidence 404(b) evidence was misused and the district court's strong disagreement with the jury about co-defendant's credibility. Therefore, the court affirmed the grant of a new trial. Accordingly, the court affirmed in part and reversed in part, remanding for a new trial.
Court Description: Criminal case - Criminal law. The district court erred in entering a judgment of acquittal as the evidence was sufficient to support the jury's finding that defendant engaged in a conspiracy to distribute crack; the district court, however, did not abuse it discretion in granting defendant's alternative motion for a new trial based on its conclusion that it had erred in allowing admission of Rule 404(b) evidence of defendant's prior drug conviction.
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