United States v. Brown, No. 18-1673 (8th Cir. 2019)
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The Eighth Circuit affirmed defendant's conviction and sentence for conspiracy to distribute 500 grams or more of methamphetamine, possession with intent to distribute methamphetamine, and involvement in a drug distribution operation.
In regard to the anticipatory warrant claim, the court held that the district court did not err in finding that the warrant was supported by probable cause and in declining to suppress the evidence on the grounds that the warrant was improperly issued, and the district court did not err in failing to suppress the evidence on the ground that the officers lacked probable cause to execute the warrant. The court also held that there was sufficient evidence to convict defendant of the charges; the district court did not err in admitting the photographs showing defendant associating with coconspirators, and their introduction did not provide a basis for a new trial; and the district court did not clearly err in denying a two-level minor role reduction, because the evidence presented at trial suggested that defendant provided protection to his codefendant and his drug trafficking operation, as well as engaged in drug purchasing and distribution himself.
Court Description: Smith, Author, with Benton and Stras, Circuit Judges] Criminal case - Criminal law and sentencing. Anticipatory warrant was supported by probable cause as it was issued after a package containing a significant quantity of methamphetamine mailed to the residence had been seized by police and even if the warrant was not properly executed after defendant picked up the package from the front steps and took it into the residence - because that was not the triggering event described in the warrant - the officers reasonably relied on the warrant to arrest defendant and seize the drugs; evidence was sufficient to support defendant's convictions for conspiracy to distribute methamphetamine and possession of the drug with intent to distribute; photos of defendant associating with other co-conspirators were properly admitted, as defendant's mere speculation that the jury might have used the photos to associate him with gang membership was not sufficient to show prejudice; the district court did not err in denying defendant's request for a minor role reduction. Stras, concurring in part and concurring in the judgment.
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