United States v. McDaniel, No. 18-1477 (8th Cir. 2019)
Annotate this CaseThe Eighth Circuit affirmed defendant's conviction and sentence for possession with intent to distribute cocaine and marijuana, possession of a firearm in relation to a drug trafficking crime, and being a felon in possession of a firearm. The court held that the district court did not abuse its discretion by permitting drug trafficking testimony from a police officer based on the specialist's experience and training; the evidence was sufficient to convict defendant of the second and third counts; the district court did not err by sentencing defendant as an armed career criminal based on his three prior convictions for selling cocaine; the sale of a controlled substance in violation of a Missouri statute is a controlled substance violation under the Armed Career Criminal Act; and defendant's sentence did not violate the Eighth Amendment.
Court Description: Benton, Author, with Smith, Chief Judge, and Stras, Circuit Judge] Criminal case - Criminal law and sentencing. In a bench trial, the district court did not abuse its discretion in admitting testimony from an experienced police officer on tools of the trade in drug dealing without conducting a Daubert hearing; evidence was sufficient to support the defendant's convictions on possession of firearms in furtherance of a drug-trafficking schemes; no error in sentencing defendant as an armed career criminal based on his three convictions for selling cocaine in violation of Section 195.211 RSMo, as the record showed there were three separate violations on three separate occasions; sale of controlled substance in violation of this Missouri statute is a controlled substance violation for sentencing under the ACCA; claim that this sentence violates the Eighth Amendment is rejected. Judge Stras, concurring. [ May 29, 2019
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