United States v. Eason, No. 15-1254 (8th Cir. 2016)
Annotate this CaseDefendant appealed his conviction for being a felon in possession of a firearm (Count 1) and for being a felon in possession of ammunition (Count 2). The court concluded that the district court did not err in excluding the dash camera video where defendant failed to show how not playing the video affected his substantial rights or had more than a slight influence on the verdict; the district court did not abuse its discretion in excluding photographs taken by a defense investigator depicting the area where the police arrested defendant and found the firearm because defendant violated Rule 16(b)(1)(A) by failing to produce them to the government in pre-trial discovery, and defendant points to no controverted issues at trial that the inclusion of the photographs would have helped resolve; the evidence was sufficient for the jury to find defendant guilty of being a felon in possession of ammunition; but, the district court erred in sentencing defendant as an armed career criminal under 18 U.S.C. 924(e)(1) where his third degree domestic battery conviction cannot categorically be determined as a crime of violence under the force clause. Accordingly, the court vacated the sentence and remanded for resentencing. The court affirmed in all other respects.
Court Description: Kelly, Author, with Murphy and Benton, Circuit Judges] Criminal case - Criminal law and Sentencing. Based on defendant's counsel's comments at the time counsel sought to use a dash cam video to impeach the arresting officer, the video was not admissible as it was extrinsic evidence and could not be used to impeach the witness; nor did the court err in denying a subsequent attempt to play the video for the jury as defendant had not disclosed the video prior to trial; in any event, defendant has failed to explain how the witness could have been further impeached by playing the video, and the court's ruling did not have a sufficient effect on his rights or the verdict so as to require a new trial; no error in refusing to admit defendant's photos of the scene as defendant had violated Rule 16(b)(1)(A) by failing to produce them to the government in pre-trial discovery; defendant has failed to show how refusal to admit the photos affected his substantial rights as there were no controverted issues the photos would have resolved; evidence was sufficient to support defendant's conviction for being a felon in possession of a firearm; defendant's prior conviction did not qualify as predicate offenses for Armed Career Criminal Act sentencing under either the residual clause or the force clause of the Act, and the matter is remanded for resentencing.
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