United States v. Needham, No. 16-1027 (8th Cir. 2017)
Annotate this CaseDefendant was convicted of possession of child pornography and distribution of child pornography. The court concluded that the district court did not abuse its discretion by admitting screenshots representing the online content of a website; the district court did not commit reversible error by admitting the Government's Exhibit 51, a summary chart containing information regarding the investigation; the district court did not abuse its discretion by denying plaintiff's requested instruction regarding the term "distribute;" and the district court did not abuse its discretion in denying defendant's motion for a new trial or his request for an evidentiary hearing because he failed to establish juror bias or misconduct. Accordingly, the court affirmed the judgment.
Court Description: Smith, Author, with Loken and Colloton, Circuit Judges] Criminal case - Criminal law. No error in admitting screenshots of a web site as the government agent testified he was familiar with the online content and that the exhibits were in the same format as the online content; the screenshots did not constitute inadmissible hearsay; no error in admission of the government's chart containing information gathered from uploaded images; no error in rejecting defendant's proposed instruction defining "distribute" in this prosecution for distribution of child pornography as the district court need not define terms of ordinary meaning and the instructions given fairly and adequately instructed the jury on the applicable law; a juror's mere distant past acquaintance with an attorney's relative does not qualify as the type of egregious or extreme situation in which juror bias may be implied or presumed, and there was no actual evidence of juror bias such as would require a new trial.
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