United States v. Scroggin, No. 10-3641 (8th Cir. 2011)
Annotate this CaseDefendant appealed the district court's denial of his motion to allow the jury to view, in person, the area beneath the console of his car where police discovered a hidden firearm. At issue was whether the district court's ruling was an abuse of discretion and violated defendant's Fifth Amendment due process right to present a defense. The court held that the district court did not abuse its broad discretion in finding a jury view of the car would be unnecessarily time-consuming and cumulative of the other evidence presented at trial. The court also rejected defendant's contention that the district court's decision violated his constitutional right to present a defense where the record revealed that defendant took full advantage of the "meaningful opportunity to present a complete defense." Therefore, the district court's denial of a jury view did not violate defendant's constitutional rights. Accordingly, the court affirmed the judgment of the district court.
Court Description: Criminal case - Criminal law. District court did not abuse its discretion by denying defendant's request to permit the jury to view his vehicle as the photographic evidence and testimony were sufficient and an actual viewing would have been time-consuming and cumulative; the decision did not deny defendant of his right to present a defense.
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