United States v. Ceeron Williams, No. 21-3122 (8th Cir. 2022)
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A jury convicted Defendant of being a felon in possession of ammunition-nine cartridge cases found at the scene of a shooting. The district court1 sentenced Defendant to 120 months’ imprisonment, the statutory maximum sentence, to be served consecutively to any undischarged term of state court sentences Defendant was serving for offenses arising out of the same incident.
He appealed the conviction and sentence, arguing the district court (i) abused its discretion in admitting lay opinion testimony by a detective of the Des Moines Police Department about what the detective saw on convenience store surveillance videos; (ii) erred at sentencing in cross-referencing to the guidelines base offense level for attempted second-degree murder, USSG Section 2A2.1; and (iii) abused its discretion in imposing a consecutive sentence.
The Eighth Circuit affirmed the district court’s judgment convicting and sentencing Defendant to 120 months’ imprisonment. The court held that Rule 701 permits the introduction of lay opinion testimony in just such circumstances. Here, there was no clear error. Defendant intervened in an altercation, firing a gun nine times at close range and striking a victim seven times. Like the conduct in United States v. Comly, this unprovoked attack with a deadly weapon “demonstrated an intent to kill or, at the very least, an act in callous and wanton disregard of the consequences to human life.” Finally, the court concluded that it agrees with the government that the district court did not abuse its “broad discretion to order a consecutive sentence to an undischarged sentence.”
Court Description: [Loken, Author, with Kelly and Kobes, Circuit Judges] Criminal case - Criminal law and sentencing. The defendant did not pose an objection to testimony from a police detective that the surveillance video shown the jury depicted "muzzle flash," and he has not preserved any objection for appellate review; even if the issue was preserved, the admission of the muzzle flash testimony was neither an abuse of the court's discretion nor plain error; in calculating defendant's base offense level, the district court did not err in applying a cross-reference to the guideline for "assault with intent to commit murder; attempted murder" rather than the cross-reference for aggravated assault as the conduct in question - an unprovoked attack where the victim was shot seven times - demonstrated an attempt to kill or, at the very least, an act in callous and wanton disregard of human life; no error in making defendant's sentence consecutive to the state court sentences he received in the matter.
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