United States v. Watson, No. 11-1169 (8th Cir. 2011)
Annotate this CaseDefendant was convicted of being a felon in possession of a firearm and ammunition, and was sentenced to 48 months' imprisonment followed by three years' supervised release. At issue was whether the district court erred in denying defendant's motion to exclude certain evidence at trial and in calculating the applicable guidelines range at sentencing. The court held that because defendant had an opportunity to effectively cross-exam both officers regarding their testimony that they observed a photo of a handgun on defendant's cell phone and a handgun holster on his person, the admission into evidence of that testimony did not offend the Confrontation Clause. The court also held that, in light of the evidence against defendant, the court was convinced that any error in admitting the challenged portions of a certain videotape would have been harmless. The court affirmed the district court's finding that the penitentiary packet records were admissible as self-authenticating public records. The court finally held that the district court did not err in assessing one criminal history point for defendant's Oklahoma conviction for possessing a firearm while committing a felony under U.S.S.G. 4A1.1(e) where possession of a firearm while committing a drug trafficking offense was similar, in kind as well as degree of risk posed, to the offenses listed in U.S.S.G. 4B1.2(a)(2). Accordingly, the court affirmed the judgment of the district court.
Court Description: Criminal case - Criminal law and sentencing. Allowing officers to testify that they observed a photo of a handgun on defendant's cell phone and a handgun holster on his person did not violate his Confrontation Clause rights because even though the officers did not preserve the evidence, defendant had the opportunity to effectively cross-examine the officers on their observations; no error in admitting video where officers informed defendant that the victim had alleged that he shot at her as the evidence was relevant to the issue of defendant's possession of a firearm; admission of defendant's Oklahoma prison records was not error; district court did not err in assessing a criminal history for defendant's Oklahoma conviction for possession of a firearm while committing a drug trafficking offense as the Oklahoma offense was a crime of violence for purposes of Guidelines Sec. 4A1.1(e).
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