United States v. Watson, No. 17-1723 (8th Cir. 2018)
Annotate this CaseThe Eighth Circuit affirmed defendant's conviction and sentence for distributing five or more grams of actual methamphetamine. The court rejected defendant's claims of evidentiary errors; the government did not impermissibly vary from the facts charged in the indictment; and the jury's verdict was supported by sufficient evidence and the district court properly denied defendant's motion for judgment of acquittal. The court also held that any procedural error at sentencing did not affect the calculation of defendant's criminal history score. Furthermore, defendant's sentence was substantively reasonable where the district court explained its sentencing decision, recounting defendant's long history of violent conduct and considered the need to protect the community. Therefore, the district court properly weighed the 18 U.S.C. 3553(a) factors and did not abuse its discretion in sentencing defendant to 180 months in prison.
Court Description: Kelly, Author, with Loken and Gruender, Circuit Judges] Criminal case - Criminal law and sentencing. Claims the court erred in admitting prior bad acts evidence and evidence regarding a controlled buy of drugs rejected; the evidence did not vary from the indictment; evidence was sufficient to support defendant's conviction for drug distribution; any error in failing to require the government to prove certain prior offenses for sentencing purposes was harmless; no error in assessing three criminal points for a theft and, in any event, the matter did not affect the calculation of defendant's criminal history score; the district court did not abuse its discretion in varying upwards based on defendant's extensive and violent criminal history, as well as the need to protect the community and keep defendant confined until he aged out of criminality.
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