United States v. Trotter, No. 15-2606 (8th Cir. 2016)
Annotate this CaseDefendant was convicted of conspiracy to distribute, and to possess with intent to distribute, methamphetamine. The court concluded that allowing an agent to testify regarding defendant's text messages did not violate the best evidence rule because the texts were admitted into evidence; the evidence was sufficient to prove that defendant entered into a conspiracy; the district court did not err in not instructing the jury first on a buyer-seller relationship; there was sufficient evidence to support the jury’s finding on the quantity of methamphetamine attributable to the conspiracy on which defendant was convicted; and the district court did not make any drug quantity findings that increased defendant's sentence above the statutory mandatory minimum sentence required by the jury’s finding in the special interrogatory. Accordingly, the court affirmed the judgment.
Court Description: Kelly, Author, with Riley, Chief Judge, and Colloton, Circuit Judge] Criminal case - Criminal law and sentencing. Introduction of testimony regarding defendant's text messages did not violate the best evidence rule as the messages were admitted into evidence; evidence was sufficient to support defendant's conspiracy conviction; court did not err in rejecting defendant's request for a "buyer-seller" instruction; the evidence supported the jury's determination that more than 500 grams of methamphetamine should be attributed to defendant, and the court properly used that amount as the "floor" for determining defendant's sentence.
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