United States v. Outlaw, No. 18-2958 (8th Cir. 2020)Annotate this Case
The Eighth Circuit affirmed defendant's conviction and sentence for conspiracy to distribute heroin and aiding and abetting the distribution of heroin. The court held that the evidence was sufficient to support the jury verdicts. In this case, ample evidence showed that defendant knowingly and intentionally joined a conspiracy to distribute heroin, and a jury could reasonably infer that defendant knew in advance that he was driving to a drug transaction and intentionally facilitated his associate's transfer of heroin.
The court also held that the district court did not err by applying a four-level sentencing increase under USSG 3B1.1(a) for an aggravating role in the offense, and a two-level sentencing increase under USSG 3C1.1 for obstruction of justice. Finally, the district court did not abuse its discretion in declining to grant a downward variance.