United States v. Rainbow, No. 15-1936 (8th Cir. 2016)
Annotate this CaseDefendants Christopher and Jordan were found guilty of assault with a dangerous weapon and assault resulting in serious bodily injury, both in violation of 18 U.S.C. 2, 113, and 1153. The court concluded that the admission of the certificates of the degree of Indian blood did not violate Christopher’s and Jordan’s Sixth Amendment rights because they were admissible as non-testimonial business records. In this case, the enrollment clerk here did not complete forensic testing on evidence seized during a police investigation, but instead performed the ministerial duty of preparing certificates based on information that was kept in the ordinary course of business. Moreover, in addition to the certificates, the government elicited testimony from the deputy superintendent for trust services that Christopher and Jordan were enrolled in the Standing Rock Sioux Tribe. The court also concluded that the district court did not abuse its discretion in denying the lesser-included-offense instruction; there was no error in the district court’s questioning of the emergency room doctor; and the evidence was sufficient to convict Jordan of assault with a dangerous weapon or assault resulting in serious bodily injuries. Accordingly, the court affirmed the judgment.
Court Description: Wollman, Author, with Bright and Loken, Circuit Judges] Criminal case - Criminal law. Admission of certificates prepared by a tribal enrollment clerk certifying defendants' degree of Indian blood did not violate their Sixth Amendment Confrontation Clause rights as the clerk prepared the certificates using records maintained in the ordinary course of business by the Standing Rock Agency, and the BIA routinely issues certificates in the administration of its affairs; additionally, the government elicited testimony from the Standing Rock Sioux Tribe's deputy superintendent for trust services that defendants were enrolled members of the Tribe; no error in denying defendants' requests for lesser-included-offense instructions as the instructions were not supported by the evidence; trial court's questioning of the emergency room doctor who treated the victim merely clarified the doctor's testimony and was not grounds for reversal; evidence was sufficient to convict defendant Jordan of assault with a dangerous weapon and assault resulting in serious bodily injury.
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