United States v. Payne-Owens, No. 15-3445 (8th Cir. 2017)
Annotate this CaseDefendant appealed his sentence and conviction for possession of a firearm by a felon and unlawful drug user. The court rejected defendant's contention that the district court abused its discretion by allowing the government to present evidence that revealed and related to his gang affiliation. In this case, the government tailored its use of evidence that referenced his gang ties to merely provide context for defendant’s own words about his overlapping personal involvement with guns and gangs, and also to show he had motive to possess a real gun or ammunition; the prosecutor’s comments were fleeting and the district court issued two detailed limiting instructions; and the district court did not commit reversible error. Finally, the court concluded that the evidence was sufficient to convict defendant for being a felon in possession. Accordingly, the court affirmed the judgment.
Court Description: Riley, Author, with Murphy and Smith, Circuit Judges] Criminal case - Criminal law. Evidence indicating defendant was a member of a gang, such as Facebook posts, was properly admitted as it helped provide the jury with a total picture concerning defendant's possession of a firearm and included evidence of threats of violence which showed his intent to possess a real firearm; further, the district court twice gave the jury detailed limiting instructions concerning the evidence and its use, and this helped reduce the risk of prejudice; government's reference to the material in its closing argument, while presenting a closer question, was not a reversible error; evidence was sufficient to support defendant's conviction for being a felon in possession.
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