United States v. Earth, No. 19-1555 (8th Cir. 2021)
Annotate this Case
The Eighth Circuit affirmed defendant's conviction of assault with a dangerous weapon. The court held that the district court did not abuse its discretion in admitting hearsay evidence by admitting certain statements. The court explained that the government did not introduce the statements to prove the truth of the matters asserted, and thus the statements were not hearsay and were properly admitted into evidence. Although the court found defendant's statements at the hospital should not have been admitted, the error was harmless. The court concluded that any improperly admitted hearsay testimony did not influence or had a slight influence on the verdict.
The court also held that the district court did not err in rejecting the proposed self-defense jury instruction, and in giving the 8th Circuit Model Jury instruction on self-defense. Finally, the evidence was sufficient to support defendant's conviction for assault with a dangerous weapon.
Court Description: [Melloy, Author, with Smith, Chief Judge, and Shepherd, Circuit Judge] Criminal case - Criminal law. Challenges to the admission of statements defendant alleged were inadmissible hearsay rejected as the statements were either not admitted for the truth of the matter asserted or were admissible under various exceptions to the hearsay rule; while statements the victim made at the hospital were not admissible under any of the exceptions and were admitted for the truth of the matters asserted, the admission of the evidence was harmless in the light of all of the other evidence in the case; the district court did not err in rejecting defendant's proposed self-defense instruction and giving the 8th Cir. Model Jury Instruction on self-defense; the evidence was sufficient to support defendant's conviction for assault with a dangerous weapon.
Some case metadata and case summaries were written with the help of AI, which can produce inaccuracies. You should read the full case before relying on it for legal research purposes.
This site is protected by reCAPTCHA and the Google Privacy Policy and Terms of Service apply.