United States v. Tyrone Cameron, No. 23-2839 (8th Cir. 2024)
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Tyrone Cameron was convicted of being a felon in possession of ammunition following a three-day trial. The district court sentenced him to 120 months' imprisonment and a three-year term of supervised release. Cameron appealed, arguing that there was insufficient evidence to support his conviction, that his conviction violated the Second Amendment, that the district court should not have admitted his prior felony convictions involving firearms into evidence, and that the government engaged in prosecutorial misconduct during closing arguments.
The district court had reviewed the evidence, including surveillance footage and testimonies, and found sufficient circumstantial evidence to support Cameron's conviction. The court also admitted Cameron's prior felony convictions into evidence, which were relevant to show that Cameron knew he was a felon and knowingly possessed ammunition.
The United States Court of Appeals for the Eighth Circuit affirmed the district court's decision. The court found that a reasonable jury could have found there existed ample circumstantial evidence to support Cameron’s conviction. The court also rejected Cameron's Second Amendment challenge, noting that the Supreme Court's decision in New York State Rifle & Pistol Ass’n, Inc. v. Bruen did not cast doubt on longstanding prohibitions on the possession of firearms by felons. The court found no error in the district court's admission of Cameron's prior felony convictions, as they were relevant to the case and not unfairly prejudicial. Lastly, the court found no prosecutorial misconduct, as the government's remarks during closing arguments were permissible interpretations of the evidence.
Court Description: [Gruender, Author, with Smith, Chief Judge, and Shepherd, Circuit Judge.] Criminal case - Criminal law. Defendant's as-applied Second Amendment challenge to his conviction for possessing ammunition as a felon, in violation of 18 U.S.C. sec. 922(g)(1), is rejected, as the conviction is not plainly erroneous in light of United States v. Jackson, 69 F.4th 495 (8th Cir. 2023). A reasonable jury could have found that defendant possessed ammunition, given the ample evidence connecting him to a shooting; the district court did not err by admitting defendant's prior felony convictions involving the use of firearms, as they were not irrelevant, unfairly prejudicial, or too remote in time; and the government's allegedly improper remarks at trial were a reasonable characterization of defendant's own prior statements and did not prejudice his right to a fair trial in any event.
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