United States v. Anthony Hall, No. 21-2541 (8th Cir. 2022)
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A jury convicted Defendant of aggravated bank robbery, and the district court sentenced him to mandatory life imprisonment under the federal “three strikes” law. Defendant appealed his conviction and sentence. On appeal, Defendant argued that (A) the district court erroneously admitted evidence of his flight from the second traffic stop; (B) the jury’s verdict lacked sufficient evidence; and (C) the three strikes law is unconstitutional.
The Eighth Circuit affirmed. The court held that the district court did not clearly abuse its discretion in concluding any danger of unfair prejudice did not substantially outweigh the evidence’s probative value. Here, evidence of Defendant’s flight from the second traffic stop helped establish the government’s narrative that Defendant continually evaded police for ten days following the robbery. It also helped the jury understand why the police found Defendant, as well as incriminating evidence, in another state. Further, Defendant’s sole argument on appeal is that he was mistakenly identified as the robber. But overwhelming evidence indicates his identification was not a mistake. Finally, the court explained that based Defendant’s criminal history outlined earlier, he has proven he remains a danger to the public despite being given a second and third chance to show otherwise. The sentence imposed here was not grossly disproportionate to Defendant’s crime.
Court Description: [Grasz, Author, with Smith, Chief Judge, and Wollman, Circuit Judge] Criminal case - Criminal law and sentencing. The district court did not err in admitting evidence that defendant fled from a traffic stop as the flight, coupled with the other details in the case, supported an inference of a guilty consciousness flowing from the bank robbery defendant had committed a few days earlier; the evidence was sufficient to support defendant's conviction for aggravated bank robbery; constitutional challenges to the federal three strikes law - 18 U.S.C. Sec. 3559(c)(1)(A)(i) - rejected as the law is constitutional on its face and as applied to defendant; three strikes law's imposition of a mandatory life sentence does not violate the 8th Amendment's ban on cruel and unusual punishment.
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