United States v. Grady, No. 22-2415 (8th Cir. 2023)
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In this case, Michael Grady and Oscar Dillon, III were convicted of conspiracy to distribute and possession with intent to distribute cocaine and heroin, attempted obstruction of justice, and conspiracy to commit money laundering. They were sentenced to 226 and 187 months’ imprisonment, respectively, and each to 5 years of supervised release. The defendants appealed their convictions, arguing various issues including that their indictments should have been dismissed on Speedy Trial Act grounds, that there was insufficient evidence to support their convictions, and that the court erred in denying their motions to substitute counsel of their choice.
The United States Court of Appeals for the Eighth Circuit affirmed the convictions. First, the court found no violation of the Speedy Trial Act, as the delays in the case were justified due to its complexity. Second, the court found that there was sufficient evidence to support the defendants' convictions for drug conspiracy, money laundering conspiracy, and attempted obstruction of justice. Finally, the court held that the trial court did not abuse its discretion in denying the defendants’ motions to substitute counsel of their choice. Specifically, the court found that the potential conflict of interest was unwaivable due to the attorney's previous representation of a key government witness in the case. Therefore, the court affirmed the convictions and sentences of the defendants.
Court Description: [Shepherd, Author, with Kelly and Stras, Circuit Judges] Criminal case - Criminal law. The court need not address whether the ends-of-justice continuances granted under 18 U.S.C. Sec. 3161(h)(7) may be open ended as the continuances here were effectively limited in time by regular reevaluation; the case continued to be complex at the time of the continuances and the continuances were appropriate under the Act, and the district court properly denied defendants' Speedy Trial Act motions to dismiss; challenge to admission of bad acts evidence against defendant Dillon rejected as the evidence fell within the exceptions provided under Rule 404(b), and its probative value outweighed any prejudicial effect; defendant Grady's prior heroin conspiracy conviction was relevant, similar to the charged conduct and not too remote in time, and it was properly admitted under Rule 404(b); the evidence was sufficient to support defendants' conviction for conspiracy to distribute cocaine and heroin, as well as their convictions for conspiracy to commit money laundering and attempting to obstruct an official proceeding under 18 U.S.C. Sec. 1512(c)(2) by advising a co-conspirator to abscond; the district court did not err in denying defendant Grady's motion for substitution of counsel given counsel's potential conflict of interest and the proximity of the trial date.
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