United States v. Waloke, No. 18-1122 (8th Cir. 2019)
Annotate this CaseThe Eighth Circuit affirmed the district court's denial of defendant's post-trial motion for judgment of acquittal or new trial and sentence of three months in prison for harboring or concealing a person from arrest. The court held that the evidence was sufficient to support the jury's finding that defendant assisted the criminal by providing shelter while he was hiding from law enforcement and that she intended to prevent his discovery and arrest. In this case, defendant's delay in allowing the officers to enter and search the house, regardless of its duration, together with her false statements to investigators, support a finding that she intentionally harbored and concealed the criminal. The court rejected defendant's alternative contention that the district court abused its discretion in denying the motion for new trial. Finally, it was not a miscarriage of justice to convict her when a jury acquitted a codefendant.
Court Description: Colloton, Author, with Shepherd and Stras - Circuit Judges] Criminal case - Criminal law. Evidence was sufficient to support defendant's conviction for harboring or concealing a person from arrest in violation of 18 U.S.C. Sec. 1071; district court did not abuse its discretion in denying defendant's motion for a new trial; argument that the verdict was a miscarriage of justice because the jury acquitted her co-defendant must be rejected as there was a reasonable explanation in the evidence for why the jury distinguished between the two defendants.
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