United States v. Stephens, No. 17-2308 (8th Cir. 2018)
Annotate this CaseThe Eighth Circuit affirmed defendant's conviction for obstruction of justice for threatening to retaliate. The court held that the difference between the verdict director and the indictment was so immaterial as to be de minimis, and defendant did not suffer prejudice. The court also held that the evidence was sufficient to support a verdict that defendant threatened an individual with the intent to retaliate against the individual's client for the client's participation as a party to an official proceeding.
Court Description: Erickson, Author, with Loken and Benton, Circuit Judges] Criminal case - Criminal law. The difference between the indictment and the verdict director was so immaterial as to be de minimis and did not prejudice defendant; evidence was sufficient to support defendant's conviction for obstruction of justice based on threats of retaliation in violation of 18 U.S.C. Sec. 1513(b)(1).
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