United States v. Castleman, No. 14-3184 (8th Cir. 2015)
Annotate this CaseCastleman was charged with conspiracy to manufacture methamphetamine, maintaining drug premises, and conspiracy to possess chemicals and equipment used to make methamphetamine. Some evidence came from a traffic stop in Walnut Ridge, Arkansas and a later search of open fields on Castleman's property. The court denied motions to suppress the evidence. At trial the government also introduced evidence that he had murdered a coconspirator to prevent him from testifying. This testimony was offered over Castleman's objection as evidence of his consciousness of guilt. The jury returned a guilty verdict on all counts. At sentencing the court found that Castleman had murdered the coconspirator, applied the higher base offense level for first degree murder under U.S.S.G. 2A1.1; 2D1.1(d)(1), and sentenced him to 40 years imprisonment. The Eighth Circuit affirmed. Castleman did not show that any expectation of privacy he had in trash bags, which were visible in the open field, was objectively reasonable. Castleman admitted that the evidence as a whole was legally sufficient to support the convictions, and the jury was properly instructed regarding the value of the consciousness of guilt evidence. It was within the court's discretion to determine that the probative value of the contested evidence outweighed the danger of unfair prejudice under Rule 403.
Court Description: Murphy, Author, with Colloton and Kelly, Circuit Judges] Criminal case - Criminal law and sentencing. While arresting officer may not have had authority to arrest defendant under state law because the stop occurred outside the officer's jurisdiction, the traffic stop and arrest were supported by probable cause and did not violate defendant's Fourth Amendment rights; trash bags and a tote found in an open field had no indicia of ownership and defendant did not have a legitimate expectation of privacy in the bags; no error in admitting evidence that defendant murdered a co-conspirator who had agreed to cooperate with authorities as the court properly instructed the jury and the relevance of the evidence to the issue of consciousness of guilt was not outweighed by its possible prejudicial effect; the government needed only prove the murder by a preponderance of the evidence in order for the court to consider the murder in connection with the application of Guidelines Sec. 2A1.1 and Sec. 2D1.1(d)(1). Judge Colloton, concurring. Judge Kelly, concurring in part and dissenting in part. [ August 04, 2015
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