United States v. Gerald Cardwell, Jr., No. 22-1561 (8th Cir. 2023)
Annotate this Case
A jury found Defendant guilty of distributing a controlled substance, resulting in the death of R.L. The district court sentenced Defendant to life imprisonment. On appeal, Defendant argued that (1) the evidence was insufficient to sustain his conviction, (2) the district court erred in allowing the government to introduce evidence of Defendant’s prior drug arrests and convictions pursuant to Federal Rule of Evidence 404(b), and (3) the district court’s use of Defendant’s prior drug possession conviction to enhance his sentence is unconstitutional because it punishes Defendant more harshly than a drug distributor.
The Eighth Circuit affirmed. The court explained that viewing the evidence in the light most favorable to the jury’s verdict and drawing all reasonable inference in its favor, it held that the evidence supports the jury’s finding that Defendant distributed the drugs to R.L. Further, the court concluded that the record includes sufficient evidence from which the jury could have found that fentanyl was the but-for cause of R.L.’s death. Finally, the court held that the First Step Act did modify Section 841(b)(1)(A) and (b)(1)(B). But it did not alter the language of Section 841(b)(1)(C), the crime under which Defendant was convicted.
Court Description: [Smith, Author, with Wollman and Loken, Circuit Judges] Criminal case - Criminal law and sentencing. The evidence was sufficient to sustain defendant's conviction for distributing a controlled substance resulting in death as the government established defendant distributed the fentanyl to the victim and that it was the "but for" cause of his death; any error in admitting evidence of defendant's past drug arrests and convictions pursuant to Federal Rule of Evidence 404(b) was harmless in light of the other evidence in the case and the court's limiting instruction; the imposition of the mandatory life sentence did not violate defendant's equal protection rights as Congress had a legitimate purpose in excluding sentences imposed under 21 U.S.C. Sec. 841(b)(1)(C) from First Step Act relief.
Some case metadata and case summaries were written with the help of AI, which can produce inaccuracies. You should read the full case before relying on it for legal research purposes.
This site is protected by reCAPTCHA and the Google Privacy Policy and Terms of Service apply.