United States v. Mazzulla, No. 18-2732 (8th Cir. 2019)
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The Eighth Circuit affirmed defendant's conviction of conspiracy to distribute and possess with intent to distribute 50 grams or more of methamphetamine, possession with intent to distribute 5 grams or more of methamphetamine, and distribution of and possession with intent to distribute 50 grams or more of methamphetamine.
The court held that there was probable cause to issue a search warrant of the Folsom St. garage; because the camper was not noticeably separate from the garage, it was covered by the search warrant, whether or not it was a vehicle for Fourth Amendment purposes; and, because the April 2 search was legally conducted pursuant to a valid search warrant, the information the police gained from the April 2 search could be relied upon for the April 22 search warrant. The court also held that the district court did not abuse its discretion in denying a Franks hearing; denying an in camera review of the officer's personnel file; and admitting bad acts evidence. Finally, there was no error in the jury instruction for the lesser included offense of simple possession, and sufficient evidence supported the verdict.
Court Description: Erickson, Author, with Colloton and Kelly, Circuit Judges] Criminal Case - Conviction. Conviction for methamphetamine distribution and possession charges. Sufficient evidence was submitted for a finding of probable cause to issue search warrant of garage and of camper within the garage; the camper was not separated in any manner from the garage and appeared to be lived-in; application of automobile exception was irrelevant; because initial search was legally conducted, information gained from it could be relied upon for subsequent search. District court did not abuse its discretion in denying a Franks hearing, as any potentially misleading facts were immaterial and warrant was supported by probable cause with information redacted. District court did not abuse its discretion in denial of in camera review of officer's personnel file, as motion was based on mere speculation that file contained exculpatory and/or impeaching information. Admission of "bad acts" evidence was not an abuse of discretion, as the testimony played little role in the trial in light of overwhelming other evidence supporting convictions. Denial of lesser-included-offense of simple possession jury instruction was not an abuse of discretion. Sufficient evidence supported the verdict on every count.
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