United States v. Hall, No. 14-2742 (8th Cir. 2019)
Annotate this CaseThe Eighth Circuit affirmed defendant's conviction and death sentence for first degree murder. The court held that the district court did not abuse its discretion by trying defendant with his co-defendant; there was no error in submitting the grave-indifference-to human-life jury instruction where nothing in the federal death penalty statute says that the jury can consider a defendant's mental state once; there was sufficient evidence for the jury to find that he killed the victim in an especially heinous, cruel, or depraved manner; and claims of error regarding mitigating factors and evidentiary errors were rejected.
Court Description: Stras, Author, with Loken and Grasz, Circuit Judges] Criminal case - Criminal law and Sentencing. The district court did not err in trying defendant with his co-defendant in this murder prosecution; no error in submitting the issue of "grave indifference to human life" to the jury in the penalty phase of the prosecution; the evidence was sufficient for a jury to find defendant killed the victim in an especially heinous, cruel or depraved manner; claim that jury failed to consider mitigating factors rejected; no error in restricting the defense's cross-examination of a psychiatric expert; no error in allowing the government to prove defendant's future dangerousness by evidence of past threats, his pre-murder behavior in prison and his numerous past crimes; no error in allowing the government to introduce two letters defendant sent to the government before trial; no error in excluding defendant's "comparative proportionality" evidence; no error in directing the jury to continue its deliberations.
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