United States v. Howard, No. 19-2473 (8th Cir. 2020)
Annotate this CaseThe 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.
Court Description: [Wollman, Author, with Gruender and Kobes, Circuit Judges] Criminal case - Criminal law and sentencing. The evidence was sufficient to support defendant's convictions for being a felon in possession of ammunition and a firearm as the evidence showed defendant knowingly possessed the weapon and ammunition; no error in admitting a pawn ticket showing defendant had pawned a weapon four months earlier as it went to show knowledge and intent to possess; further, the district court gave a limiting instruction diminishing any prejudicial effect of the evidence; no error in admitting a dashcam video showing defendant escaping from an officer, as flight was evidence of consciousness of guilt; again, the district court's careful instruction on the matter lessened the potential for any prejudicial effect; defendant's Wisconsin conviction for armed robbery and North Dakota conviction for conspiracy to deliver ecstasy were qualifying offenses for Armed Career Criminal Act sentencing.
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