United States v. Sims, No. 20-1009 (8th Cir. 2021)
Annotate this CaseThe Eighth Circuit affirmed defendant's conviction and sentence for unlawfully distributing methamphetamine and of conspiring to distribute it. The court concluded that, viewed in the light most favorable to the verdict, a single conspiracy existed. Furthermore, even if a variance occurred, reversal is warranted only if it infringes on defendant's substantial rights. In this case, defendant raised neither notice nor double-jeopardy concerns, only asserting a spillover of evidence from one conspiracy to another. The court concluded that the evidence of defendant's participation in one conspiracy would have been probative of his intent to participate in the other and was therefore admissible. Furthermore, the jury instructions also reduced any risk of prejudice. The court also concluded that there was no error in admitting statements under the coconspirator exception because they were not in furtherance of the conspiracy, in not separately polling a juror, and in calculating drug quantity.
Court Description: [Benton, Author, with Gruender and Shepherd, Circuit Judges] Criminal Case - conviction and sentence. Sims appeals his conviction for unlawfully distributing methamphetamine and conspiring to distribute it, and his 108 month sentencing, arguing the evidence presented proved multiple conspiracies but the indictment alleged only one, the district court erroneously admitted hearsay, abused its discretion in not polling a juror in isolation and erred in calculating the drug quantity attributable to Sims. Viewed in the light most favorable to the verdict, one conspiracy existed, a reasonable juror could conclude there was a single conspiracy, and the district court did not clearly err in denying a motion to acquit. Even if a variance occurred, Sims's substantial rights were not infringed. District court did not err in admitting statements made in furtherance of the conspiracy, did not abuse its discretion in not separately polling the juror, and did not clearly err in calculating drug quantity.
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