United States v. Thomas, No. 11-1432 (8th Cir. 2011)
Annotate this CaseDefendant was convicted of first degree murder and sentenced to life imprisonment. Defendant appealed from his conviction. The court held that the district court did not err in denying defendant's motion to suppress statements he made at his mother's home and a subsequent confession where defendant's statements made in his mother's home were made in a non-custodial setting; his subsequent confession was not excluded based on an earlier unwarned statement; and any error in admitting the statements made in the house would have been harmless. The court also held that the district court did not err in denying defendant's motion for judgment of acquittal where there were multiple constructions of the evidence that supported the jury's verdict. The court further held that the district court did not err in denying defendant's motion for mistrial based on prosecutorial misconduct where the instances of misconduct, whether viewed singly or cumulatively, did not deprive defendant of a fair trial. Accordingly, the conviction was affirmed.
Court Description: Criminal case - Criminal law. Defendant's statements were made in a non-custodial setting and were admissible; subsequent confession was not the fruit of the poisonous tree; in any event, any error in admitting the statements was harmless in light of the overwhelming, independent evidence of defendant's guilt; evidence was sufficient to support defendant's conviction for first-degree murder; claims of prosecutorial misconduct rejected.
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