United States v. Blakeney, No. 16-3945 (8th Cir. 2017)
Annotate this CaseThe Eighth Circuit affirmed defendants' conviction of conspiracy against rights, deprivation of rights under color of law, and falsifying a record. The court held that the evidence was sufficient to support defendant's conviction for illegal arrest where a reasonable jury could find that another person, the Mayor, conspired with defendant to arrest a mayoral candidate. The court also held that the district court did not plainly err by admitting an unsigned copy of the incident report under the best evidence rule; the district court did not plainly err by permitting hearsay testimony from the Mayor because the Mayor was the coconspirator; the Government's comment during closing was not improper; the district court did not err by responding to the jury's question regarding the charge of falsifying a document; defendant's absence during a jury question about a transcript did not prejudice him; and defendant was not entitled to have the jury review a transcript of the government's witnesses' testimony.
Court Description: Gruender, Author, with Wollman and Melloy, Circuit Judges] Criminal case - Criminal law. Evidence was sufficient to support defendant's conviction for conspiring to deprive a person of her civil rights; the government presented facts which would allow a reasonable jury to conclude that there was an agreement between defendant, a Pine Lawn, Missouri police officer, and the city's mayor; the evidence was also sufficient to show defendant deprived a mayoral race candidate of her civil rights under color of state law by having her illegally arrested; no error in admitting an unsigned copy of the police department incident report which gave rise to the arrest as the admission did not violate the best evidence rule; no error in admitting a co-conspirator's statement made during the course of and in furtherance of the conspiracy; prosecutor's comments in closing argument were not an improper comment on defendant's failure to testify; district court did not err in its response to the jury's question regarding the charge of falsifying a document; defendant's absence when the court answered a question from the jury about a transcript did not prejudice him as the judge gave both parties a chance to object and comment once he had "tracked everyone down;" defendant was not entitled to have the jury review a transcript of the government's witnesses' testimony.
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