United States v. Delgrosso, No. 16-1980 (8th Cir. 2017)Annotate this Case
Defendants Delgrosso and Cain were convicted of conspiracy to distribute methamphetamine, money laundering, and conspiracy to commit money laundering. Delgrosso also was found guilty of failing to file IRS Form 8300. The court concluded that the district court did not abuse its discretion in denying defendants' motions for a new trial based on Jerry Wright's post-trial affidavit because, even if Wright testified or the affidavit were admitted, the Government could impeach Wright's credibility by introducing evidence of his seven prior felony convictions. Furthermore, even if the jury believed Wright's statements, that does not mean that it would likely acquit defendants. In this case, the Government provided ample evidence that would allow the jury to conclude that Delgrosso and Cain knew or willfully blinded themselves to the fact that Wright acquired his cash through drug sales. The court also concluded that the district court did not abuse its discretion in denying Delgrosso's motion for a new trial based on Government misconduct under Brady v. Maryland where it was untimely and, even if it was timely, his allegations either relate to issues that were irrelevant or were directly contradicted; the district court did not plainly err by instructing the jury on willful blindness; the district court did not err in denying Delgrosso's motion for acquittal where sufficient evidence supported the jury's verdict; and the district court did not clearly err in denying Delgrosso safety-valve relief. Accordingly, the court affirmed the judgment.