United States v. Metcalf, No. 16-4006 (8th Cir. 2018)
Annotate this CaseThe Eighth Circuit affirmed defendant's conviction of committing a hate crime in violation of the Matthew Shepard and James Byrd, Jr., Hate Crimes Prevention Act of 2009, 18 U.S.C. 249(a)(1). The court held that the district court did not err in denying defendant's motion to dismiss the indictment on constitutional grounds where Congress rationally determined, in light of the Thirteenth Amendment, that racially motivated violence constitutes a badge and incident of slavery; the district court did not abuse its discretion in refusing to give the proposed jury instruction on character evidence; and the evidence was clearly sufficient to support the conviction.
Court Description: Wollman, Author, with Smith, Chief Judge, and Gruender, Circuit Judge] Criminal case - Criminal law. Constitutional challenge to the Matthew Shephard and James Byrd, Jr., Hate Crimes Prevention Act of 2009, 18 U.S.C. Sec. 249(a)(1) rejected as Congress had the authority, under the Thirteenth Amendment, to enact the legislation; evidence was sufficient to support defendant's conviction for violating the Act; no error in denying the defendant's request for a proposed instruction on character evidence.
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