United States v. Aldridge, No. 11-1344 (8th Cir. 2011)
Annotate this CaseDefendant was convicted of conspiring to distribute 500 grams of methamphetamine and was sentenced to life imprisonment. Defendant appealed his conviction and sentence. The court held that the district court did not err in denying defendant's motion to suppress his confessions and the resulting evidence where defendant was not in custody and defendant acquiesced to questioning; while the district court abused its discretion in admitting two prior convictions, the error was harmless; there was sufficient evidence for a reasonable jury to conclude beyond a reasonable doubt that defendant conspired to distribute meth; and defendant's mandatory life sentence did not violate the Eighth Amendment. Accordingly, the judgment was affirmed.
Court Description: Criminal case - Criminal law and sentencing. District court did not err in finding defendant's confession was admissible as he was not in custody at the time he made the statements, and the statements were not obtained through improper coercion or deception; while it was error to admit evidence of two of defendant's four prior drug felony convictions because they were too remote in time, the error was harmless as the evidence was merely cumulative and the district court gave a proper limiting instruction; evidence was sufficient to support defendant's conviction for conspiracy to distribute methamphetamine; mandatory life sentence does not violate the Eighth Amendment's prohibition on cruel and unusual punishment.
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