United States v. Jefferson, No. 19-3159 (8th Cir. 2020)
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The Eighth Circuit held that the evidence was sufficient to convict defendant of possession with intent to distribute marijuana, possessing a firearm in furtherance of a drug trafficking crime, and being a felon in possession of a firearm. The court also held that the district court did not abuse its discretion in denying defendant's motion for a new trial where the government's closing argument was permissible under Federal Rule of Evidence 404(b); there was no error in admitting forensic testimony by the government's experts because their testimony on the absence of DNA and fingerprints on the firearms and ammunition was relevant and helpful to the jury; and there was no error in admitting a photo of defendant in handcuffs where the district court gave a cautionary instruction.
The court further held that the district court did not err by sentencing defendant as a career offender under USSG 4B1.1(a); by imposing an enhancement under USSG 2D1.1(b)(12) for maintaining a drug premises; and by imposing an enhancement under USSG 3B1.1 for leadership role in the offense. Accordingly, the court affirmed defendant's conviction and sentence.
Court Description: [Loken, Author, with Grasz, Circuit Judge, and Clark, District Judge] Criminal case - Criminal law and sentencing. Evidence was sufficient to support defendant's convictions for possession of marijuana with intent to distribute, possession of a firearm in furtherance of a drug trafficking crime and being a felon in possession of a firearm; the district court did not abuse its discretion in denying defendant's motion for new trial as: (1) the government's closing argument stayed within the permissible parameters of Rule 404(b); (2) the court did not err in admitting forensic testimony by the government's experts as their testimony on the absence of DNA and fingerprints on the firearms and ammunition was relevant and helpful to the jury; and (3) the court did not err in admitting a photo of defendant in handcuffs taken during the warrant search as the photo established defendant's presence, and the court gave a cautionary instruction that the fact that defendant was in handcuffs was not indicative of anything and was done for safety purposes; the court did not err err in sentencing defendant as a career offender under Chapter 4 of the Guidelines as his drug offenses qualified as controlled substance offenses; no error in imposing an enhancement under Guidelines Sec. 2D1.1(b)(12) for maintaining a drug premises; no error in imposing an enhancement under Guidelines Sec. 3B1.1 for leadership role in the offense.
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