United States v. Maria Nava, No. 22-2914 (8th Cir. 2023)
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Defendant and co-Defendant were convicted of conspiracy to distribute methamphetamine and, conspiracy to commit money laundering, and possession of firearms in furtherance of a drug trafficking crime. Co-Defendant was also convicted of illegal re-entry. Defendant challenged the sufficiency of the evidence against her, and co-Defendant contends the district court abused its discretion when it refused to allow witnesses who are Mexican nationals to testify by Zoom and admitted evidence of an unrelated assault with a firearm.
The Eighth Circuit affirmed in part and reversed in part the district court’s denial of Defendant’s motion for judgment of acquittal and vacated her conviction for conspiracy to commit money laundering. The court reversed the district court’s denial of Defendant’s motion for a new trial on the drug trafficking and firearms counts and remanded for proceeding. The court affirmed with respect to co-Defendant. The court explained that it is unable to determine whether the district court abused its discretion by not considering a matter that should have been given significant weight by giving significant weight to something improper or irrelevant or if it committed a clear error of judgment. Therefore, the court remanded to the district court for consideration of Defendant’s motion for a new trial as it relates to the drug trafficking conspiracy and related firearms count.
Court Description: [Erickson, Author, with Smith, Chief Judge, and Melloy, Circuit Judges] Criminal case - Criminal law. The court could not say that the evidence of defendant De La Cruz Nava's involvement in a conspiracy to distribute drugs was so lacking that no reasonable jury could have found her guilty beyond a reasonable doubt, and the district court did not err in denying her motion for a judgment of acquittal; however, on this record, the court cannot determine whether the district court properly applied the standard for reviewing a motion for new trial under Rule 33, and the matter is remanded to the district court for consideration of defendant De La Cruz Nava's motion for a new trial as it relates to the drug trafficking conspiracy and related firearms count; the government did not meet its burden to establish that De La Cruz Nava was involved in a conspiracy to commit money laundering, and her conviction on that count is reversed; the district court did not err in ruling that defendant Guzman's Mexico-based alibi witnesses could not appear by Zoom; the district court did not err in admitting evidence that defendant Guzman committed an unrelated assault as it was relevant to establish knowledge of weapons and intent to use them, and the probative value of the evidence was not outweighed by the risk of unfair prejudice. [ September 05, 2023 ]
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