United States v. Dones-Vargas, No. 18-2600 (8th Cir. 2019)Annotate this Case
The Eighth Circuit affirmed defendant's conviction for two drug trafficking offenses. The government had been unaware of payments that local police made to a cooperating witness and thus failed to disclose the information to the defense. Defendant moved for a new trial based on the nondisclosure. The court held that the undisclosed payments were not material to the outcome of the proceeding and thus the district court did not err by denying defendant's motion for a new trial. In this case, the impeachment value of the payment information was not so devastating as to undermine the entire prosecution.