United States v. Williams, No. 18-1445 (8th Cir. 2020)Annotate this Case
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.