United States v. St. Claire, No. 15-3665 (8th Cir. 2016)
Annotate this CaseDefendant was convicted of three counts of aggravated sexual abuse and three counts of abusive sexual contact. The court concluded that the district court did not abuse its discretion in admitting a fourth witness's testimony under FRE 414 where the testimony is probative and tends to show propensity, and where the fact that the testimony was cumulative does not substantially outweigh the probative value of the testimony. The court also concluded that the district court did not abuse its discretion in imposing a life sentence, which was within the Guidelines range, where the district court considered the 18 U.S.C. 3553(a) factors. Accordingly, the court affirmed the judgment.
Court Description: Shepherd, Author, with Murphy and Bright, Circuit Judges] Criminal Case - conviction and sentence. The district court did not abuse its discretion in allowing a fourth witness, with whom St. Claire had not been charged with assaulting, to testify under Rule 414 about defendant's abuse; fact that testimony was cumulative does not substantially outweigh its probative value, as it was probative of the consistency of the abuse and showed defendant's propensity. Life sentence was within the guidelines range and the court did not abuse its discretion in imposing a life sentence.
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