United States v. Eric Ladeaux, No. 22-1623 (8th Cir. 2023)
Annotate this Case
A jury convicted Defendant of two counts of felon-in-possession and one count of possessing an unregistered firearm. Defendant brought three challenges. First, he argues that Standing Order 19-03 and Standing Order 16-043 denied him his constitutional right to prepare for trial. Second, he claims the district court erred in declining to give his requested jury instruction on duress and coercion. Finally, he challenges the evidentiary sufficiency of his conviction.
The Eighth Circuit. The court held that because Defendant did not show the absence of legal alternatives to firearm possession, the district court did not abuse its discretion in declining to instruct the jury on coercion/duress. Further, the court reasoned that Defendant’s own statements support the verdict. Although he was one of many passengers in the car that held the gun, he told officers that he “wouldn’t charge the other passengers with the gun” and joked that he might have held the other passengers hostage with a “12-gauge.” Officers testified that Defendant had never been told that a gun was found in the car, much less that it was a 12-guage. Police found the sawed-off shotgun under the passenger seat where Defendant sat. The gun’s stock was positioned toward him, bullets at his feet. Defendant’s knowledge that the car held a 12-gauge shotgun, the gun’s position, and his proximity to it support an inference that he knowingly possessed the gun.
Court Description: [Benton, Author, with Erickson, Circuit Judge, and Buescher, District Judge] Criminal case - Criminal law. Applying a plain error analysis, two South Dakota District Court Standing Orders (19-03 and 16-04) concerning a confined defendant's access and retention of sealed documents do not require reversal as the general purpose of the rules - safety of inmates and integrity of ongoing investigations - provide the good cause required under Federal Rule of Criminal Procedure 16(d); the evidence did not support defendant's request for a jury instruction on duress and coercion in this firearm possession prosecution; the evidence was sufficient to show defendant knowingly possessed a sawed-off shotgun; an argument raised for the first time in a reply brief is waived.
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.