United States v. Bradley, No. 18-2295 (8th Cir. 2019)
Annotate this CaseThe Eighth Circuit affirmed defendant's conviction for possession with intent to distribute cocaine and cocaine base, and being a felon in possession of a firearm. The court held that probable cause supported the issuance of a warrant to place a GPS tracker on defendant's vehicle; the district court did not err by denying defendant's request for a Franks hearing or his request to compel the disclosure of the identities of confidential informants and tipsters; the evidence was sufficient to convict defendant of the crimes; and the district court properly admitted statements from defendant's recorded post-arrest phone calls as evidence of the direct consciousness of guilt.
Court Description: Benton, Author, with Smith, Chief Judge, and Stras, Circuit Judges] Criminal case - Criminal law. Warrant application to place a GPS tracker on defendant's car established probable cause; the district court did not err in denying defendant's request for a Franks hearing; nor did the court err in denying his request to compel the disclosure of the identities of a confidential informant and tipsters; evidence was sufficient to sustain defendant's convictions for being a felon in possession and for possession of drugs with intent to distribute; statements from defendant's recorded post-arrest phone calls were properly admitted as his statements expressed concern about the charges, which is admissible as direct consciousness of guilt.
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