United States v. Sims, No. 14-2008 (8th Cir. 2015)
Annotate this CaseSims was charged as a felon in possession of a firearm. A magistrate ordered that the government disclose all expert testimony by April 10. Trial was set for April 28. Immediately after arresting Sims, officers sent a gun seized from him to a crime lab for DNA testing. The lab mistakenly believed that it did not have a DNA sample from Sims for comparison. The analyst e-mailed a detective, who did not respond. Nor did the analyst hear from prosecutors. Meanwhile, Sims and the government discussed a potential plea. The deadline passed. On April 14, Sims’s lawyer announced that Sims would not plead guilty. The government contacted the lab about the DNA tests. The lab then located a DNA sample from Sims. The government did not tell the court or Sims that it was awaiting DNA evidence, did not update its expert-witness list, and stated, at the April 17 pretrial conference, that it was ready for trial. On April 21, the lab reported that Sims was the source of most of the DNA on the gun. The next day, the government sent Sims’s attorney a copy of the report and information about its expert witness and filed a “Supplemental Notice of Expert Witnesses.” The district court excluded the testimony, reasoning that the government acted with reckless disregard for the deadline and that the evidence would cause “extreme prejudice.” The Eighth Circuit affirmed.
Court Description: Criminal case - Criminal law. The district court did not abuse its discretion by excluding DNA evidence where the government, in reckless disregard of the court's orders, failed to produce the test results within the time established for discovery and where a continuance, or a lesser sanction, would not have been an adequate remedy.
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