United States v. Williams, No. 18-1445 (8th Cir. 2020)
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The Eighth Circuit affirmed defendant's conviction for one count of felon in possession of a firearm, two counts of possession with intent to distribute cocaine and marijuana, one count of maintaining a premise for the purpose of distributing a controlled substance, and one count of possessing a firearm in furtherance of a drug trafficking crime.
The court held that the district court did not abuse its discretion by admitting evidence seized after a warrantless protective sweep under the plain view doctrine; defendant failed to show that the government deleted any exculpatory evidence; defendant validly waived his right to proceed with a jury trial; and the district court did not err in denying defendant's motion to proceed pro se.
Court Description: [Kobes, Author, with Gruender and Stras, Circuit Judges] Criminal case - Criminal law. When police entered the house, the scene of a home break-in, and saw firearms and drugs strewn on the floor, they were entitled to seize the evidence under the plain view doctrine, and the district court properly denied defendant's motion to suppress the evidence; the district court did not err in denying defendant's motion to dismiss premised on a theory that the government intentionally destroyed or altered exculpatory evidence on his home security DVR as there was no evidence the government deleted any evidence from the system, let alone exculpatory evidence; nor was there any evidence the police tampered with the recorded images; defendant validly waived his right to a jury trial; under the facts presented the district court did not err in denying defendant's motion to proceed pro se, which was made on the morning of trial.
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