United States v. Howard, No. 19-2473 (8th Cir. 2020)Annotate this Case
The Eighth Circuit affirmed defendant's conviction and sentence for being a felon in possession of a firearm and ammunition. The court held that the evidence was sufficient to support defendant's conviction because it showed defendant knowingly possessed the weapon and ammunition; the district court did not abuse its discretion by admitting a pawn ticket in order to show knowledge and intent to possess the weapon, and the district court's instruction limited any prejudicial effect of the evidence; and the district court did not abuse its discretion by admitting a dashcam video showing defendant escaping from an officer because flight was evidence of consciousness of guilt. Finally, the court held that defendant's prior Wisconsin conviction for armed robbery and North Dakota conviction for conspiracy to deliver ecstasy are qualifying offenses for Armed Career Criminal Act sentencing.