United States v. Hollingshed, No. 17-2951 (8th Cir. 2019)
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The Eighth Circuit affirmed defendant's conviction for being a felon in possession of a firearm. The court rejected defendant's claim under Rehaif v. United States, 139 S. Ct. 2191 (2019), and held that there was no plain error where defendant failed to show a reasonable probability that, but for the error, the outcome of the proceeding would have been different. Assuming without deciding that the district court erred in admitting a photo lineup identification in violation of defendant's Sixth Amendment right to confrontation, the court held that admission of such evidence did not affect defendant's substantial rights.
The court also held that the evidence was sufficient for a reasonable jury to find defendant guilty beyond a reasonable doubt. Finally, the court held that the district court did not abuse its discretion by imposing two special conditions for defendant's supervised-release term --requiring defendant to participate in anger management treatment and domestic violence treatment -- in light of defendant's behavior problems in the past.
Court Description: Smith, Author, with Loken and Gruender, Circuit Judges] Criminal case - Criminal law and sentencing. Defendant's Rehaif issue would be reviewed under the plain error standard and defendant could not establish that any error affected his substantial rights or seriously affected the integrity of the judicial proceedings in his case; assuming, without deciding, that the district court plainly erred in admitting photo identification evidence testimony from a police officer and that defendant did not waive his Confrontation Clause rights, the admission of the evidence did not affect defendant's substantial rights as the admissible evidence in the case overwhelmingly established defendant possessed a firearm; evidence was sufficient to support defendant's conviction for being a felon in possession of a firearm; no error in imposing special conditions of supervised release which require defendant to under anger management counseling and domestic violence treatment.
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