United States v. Watson, No. 17-2558 (8th Cir. 2018)
Annotate this CaseThe Eighth Circuit affirmed defendant's conviction and sentence for multiple offenses related to a counterfeiting scheme. The court held that the evidence was sufficient to sustain a conviction for making counterfeit securities where the checks at issue qualified as an "implement" under 18 U.S.C. 513(b); the sentencing judge made an independent determination to run the sentence in another case consecutive to the sentence in this case and explained on the record the facts that he believed supported a consecutive sentence; the consecutive nature of the sentences was eminently reasonable given that defendant's additional criminal conduct was committed while he was in custody on the charges in this case; and defendant failed to present any legal or factual basis to support withdrawal of his guilty pleas.
Court Description: Erickson, Author, with Colloton and Benton, Circuit Judges] Criminal case - Criminal law and sentencing. The evidence was sufficient to support defendant's conviction for possessing an implement suitable for making counterfeit securities in violation of 18 U.S.C. Sec. 513(b); evidence that defendant possessed photocopied checks was sufficient to satisfy the "implement" element of the statute; such checks are particularly suited for use in counterfeiting and qualified as an implement; issue concerning the district court's decision to make defendant's sentence consecutive to a sentence yet to be imposed by the same judge was moot; the district court did not err in denying defendant's motion to withdraw his guilty plea to two counts as his claim that he was confused about what he was pleading to was directly contradicted by the plea colloquy.
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