United States v. Wright, No. 19-3190 (8th Cir. 2021)
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The Eighth Circuit affirmed defendant's conviction and sentence for carjacking; two counts of carrying a firearm during and in relation to a crime of violence; and possession of a firearm by a prohibited person.
The court concluded that the district court did not abuse its discretion in admitting government exhibits at trial related to a photo on defendant's Facebook, Facebook conversations, and a video of defendant with a firearm while counting a large amount of cash. The court also concluded that the district court did not abuse its discretion in instructing the jury on the "intent" element of carjacking and the phrase "carried a firearm" in 18 U.S.C. 924(c); the evidence was sufficient to support defendant's convictions for carjacking, carrying a firearm in relation to a crime of violence, and possession of a firearm by a prohibited person; and the district court did not err in imposing an enhancement under USSG 2K2.1(b)(1) for possession of between 3 and 7 firearms, and in applying the carjacking offense characteristic under USSG 2B3.1(b)(5).
Court Description: [Smith, Author, with Wollman and Loken, Circuit Judges] Criminal case - Criminal law and sentencing. The district court did not err in admitting eight government exhibits showing defendant with cash and guns, discussing his possession of the firearm used in the charged offenses and showing his contact with his co-defendant on the day of the robbery and also his location near the phone taken in the carjacking; challenge to instruction on carjacking rejected; instructions defining "carried a firearm" were not erroneous; evidence was sufficient to support defendant's convictions for carjacking, carrying a firearm in relation to a crime of violence, and possession of a firearm by a prohibited person; no error in imposing an enhancement under Guidelines Sec. 2K2.1(b)(1) for possession of between 3 and 7 firearms; nor did the court err in imposing an enhancement under Guidelines Sec. 2B3.1(b)(5), the carjacking offense characteristic, as Sec. 2B3.1 and the corresponding base level of 20 did not fully account for defendant's conduct; imposition of the enhancement was not double counting.
The court issued a subsequent related opinion or order on April 21, 2021.
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