United States v. Watson, No. 17-2558 (8th Cir. 2018)Annotate this Case
The 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.