United States v. Sharron, No. 20-1427 (8th Cir. 2021)
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The Eighth Circuit affirmed defendant's conviction for robbing an individual of personal property belonging to the United States. The court held that the district court did not err in denying defendant's request for instructions on duress or coercion and/or voluntariness as he failed to meet his burden of proving the existence of duress/coercion by a preponderance of the evidence. In this case, defendant's evidence amounts to a generalized and speculative fear of violence, and is insufficient to demonstrate the requisite showing of a present, imminent, and impending threat.
Even if defendant had established a fear that was immediate and well-founded, the court explained that defendant's duress defense would still fail because he cannot show he had no reasonable, legal alternative to engaging in the robbery. Finally, upon careful review of the record, the court found that the court did not prohibit defendant from arguing his theory of defense.
Court Description: [Erickson, Author, with Benton and Grasz, Circuit Judges] Criminal case - Criminal law. The district court did not err in denying defendant's request for instructions on duress or coercion and/or voluntariness as he failed to meet his burden of proving the existence of duress/coercion by a preponderance of the evidence; his evidence amounted to a generalized and speculative fear of violence and was insufficient to demonstrate the requisite showing of present, imminent and impending threat; nor did he show that he had no reasonable, legal alternative to engaging in the offense conduct; the record showed the district court did not prohibit defendant from arguing his theory of defense and his claim that he was prohibited is rejected. [ January 20, 2021 ]
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