United States v. West, No. 15-3026 (8th Cir. 2016)
Annotate this CaseDefendant was convicted of three counts of tax evasion and sentenced to 51 months in prison, as well as three years of supervised release. Defendant contends that he was entitled to present provisions of the Internal Revenue Code and other material to the jury for the purpose of supporting a mistaken-belief defense. The court affirmed the district court's evidentiary rulings, concluding that the right to present a complete defense does not entitle a defendant to present the jury with evidence that is either irrelevant or is properly excluded under Federal Rule of Evidence 403. The court concluded that Special Condition 13, which requires that defendant refrain from creating or establishing any new websites and that he remove any of his currently existing websites, and Special Condition 14, which bans defendant from using or possessing computing devices without prior written approval from a probation officer and requires him to consent to searches of any computer he is permitted to possess, are both overly broad. Accordingly, the court affirmed the district court's evidentiary rulings but vacated the challenged special conditions of supervised release and remanded for resentencing.
Court Description: Beam, Author, with Loken and Smith, Circuit Judges] Criminal case - Criminal law and sentencing. The district court's evidentiary rulings did not deprive defendant of his ability to present a mistaken-belief defense in this tax fraud prosecution; Special Conditions #13 of defendant's supervised release which prevents him from creating any new websites and requires him to remove any existing websites is overly broad; Special Condition #14, which bans defendant from using or possessing computing devices without prior written approval and subjects him to searches of any computer he does own, is also overly broad; these two conditions are vacated and the matter is remanded for resentencing.
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