United States v. Woods, No. 18-3057 (8th Cir. 2020)Annotate this Case
The Eighth Circuit affirmed Defendants Woods and Shelton's convictions for crimes involving bribes and kickbacks using public funds. The court held that the district court did not err in denying defendants' motion to dismiss based on an FBI agent's misconduct in destroying evidence. In this case, there is simply nothing to connect the dots between the agent's destruction of his computer data and the underlying cases against defendants and others as proven largely through records held by third-party custodians unrelated to and unaffected by the agent. Furthermore, in granting the government's motion to exclude evidence of the agent's bad acts, there was no error in the district court's assessment of potential prejudice, confusion of issues, wasting of time, or in the balancing of these issues.
The court also held that the district court did not abuse its substantial discretion in denying a motion for a continuance. To the extent Woods and Shelton argue Instruction 7 as originally given, or as amended, misstated the law, the court rejected their argument; to the extent Woods and Shelton argue the district court violated their Sixth Amendment rights by engaging in ex parte communication with the jury, the court rejected their argument due to a lack of prejudice; and the court rejected the remaining challenges to the jury instructions. Finally, the district court did not abuse its discretion in denying the motion for recusal.