United States v. Williams, No. 23-2149 (8th Cir. 2024)
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In this case heard before the United States Court of Appeals for the Eighth Circuit, the defendant Ricky Timothy Williams was convicted of possession with intent to distribute 50 grams or more of methamphetamine, possession of a firearm in furtherance of a drug trafficking crime, and being a felon in possession of a firearm. Williams appealed his conviction, arguing that the district court erred by giving a supplemental instruction to the jury that he believed went beyond the scope of the jury's question and was duplicative of instructions already given.
The Court of Appeals affirmed the conviction, stating that the district court has the discretion to respond to a jury's request for a supplemental instruction. The Court of Appeals found that the instructions given by the district court, when taken as a whole, fairly and adequately instructed the jurors on the applicable law. They also found that the supplemental instruction was not unnecessarily duplicative, and that district courts are not prohibited from giving duplicative instructions where reinstruction will assist the jury.
The Court of Appeals also noted that the jury's note to the court made clear that they were confused about the meaning of a phrase from the final instruction. The district court clarified this confusion by providing a supplemental instruction using language from the final instructions already given, and the Court of Appeals found this to be within the district court's discretion.
Court Description: [Benton, Author, with Erickson and Kobes, Circuit Judges] Criminal case - Criminal law. Defendant's challenge to a supplemental instruction given in response to jury questions on the instruction setting out the elements of the offense for possession of a firearm in furtherance of a drug trafficking crime is rejected as the instruction, taken as a whole, fairly and adequately instructed the jurors on the applicable law, and the district court did not abuse its discretion in giving the instruction.
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