United States v. Haynes, No. 19-1607 (8th Cir. 2020)
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The Eighth Circuit affirmed defendant's conviction and sentence for being a felon in possession of a firearm. The court held that the government did not violate the Speedy Trial Act, and defendant failed to offer any evidence showing that Iowa and federal prosecutors colluded. Furthermore, the district court did not abuse its discretion by failing to hold an evidentiary hearing regarding the existence of collusion.
The court also held that the district court did not err in denying the motion to suppress where defendant was not unlawfully seized. In this case, prior to producing the marijuana cigarette, the officer did not ask defendant any questions but merely ordered him off the bus, particularly as the smell of marijuana alerted the officer that evidence of a more serious crime than failure to use a turn signal might be uncovered during the stop. Finally, the court held that defendant was not unlawfully searched when the officer conducted a pat-down search incident to arrest; the evidence was sufficient to support defendant's conviction; defendant's Rehaif claim failed because there was sufficient evidence that he knew of his prohibited status; and defendant's sentence was not substantively unreasonable nor an abuse of the district court's discretion.
Court Description: [Gruender, Author, with Smith, Chief Judge, and Loken, Circuit Judge] Criminal case - Criminal law and sentencing. Speedy Trial Act claim rejected; officers lawfully ordered defendant off a party bus, particularly as the smell of marijuana alerted the officers that a more serious crime than the initial traffic infraction was involved; after defendant voluntarily produced a marijuana joint, officers had probable cause to arrest him and pat him down; evidence was sufficient to support defendant's firearm conviction; Rehaif argument rejected as there was sufficient evidence that he knew of his prohibited status;sentence was not substantively unreasonable or an abuse of the district court's discretion.
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