United States v. Alfred Jackson, 856 F.3d 1187

In 2014–2015 Iowa City investigators targeted a heroin distribution ring; Jason Dawson identified Alfred Jackson as a supplier and Curtis Kemp as a participant.
Law enforcement executed controlled buys, searched Dawson’s vehicle and residence, and obtained warrants for phone data; Dawson cooperated and recorded conversations with Jackson.
Police searched Jackson’s residence and found evidence consistent with heroin distribution, including a phone linked to Dawson’s texts; Jackson and Kemp were arrested and indicted in a superseding indictment charging conspiracy and distribution of heroin.
Before trial the government gave notice of intent to introduce Rule 404(b) evidence; at trial the government presented (1) testimony about a 2010 search of Kemp’s apartment (drugs/paraphernalia) and (2) testimony from Ricky Jones that he and Kemp used heroin together.
A jury convicted Jackson and Kemp; district court sentenced Jackson to 188 months and Kemp to 84 months. Both appealed; the Eighth Circuit affirmed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Admissibility of prior-bad-acts under Fed. R. Evid. 404(b) (Kemp)	Gov't: prior drug evidence shows intent, knowledge, plan, motive relevant to conspiracy	Kemp: 2010 search and Jones's testimony irrelevant or unduly prejudicial and cumulative	Court: Admission proper — evidence relevant to mental state/intent, similarity and timing adequate, limiting instruction mitigated prejudice; no abuse of discretion
Sufficiency of evidence for conspiracy (Jackson)	Gov't: Dawson's testimony, phone records, recorded call, ledger, and residence evidence establish agreement, knowledge, and voluntary joining	Jackson: Dawson was unreliable; testimony inconsistent and insufficient	Court: Evidence construed in gov't favor supports conviction; credibility for jury; conviction affirmed

United States v. Wilson, 619 F.3d 787 (reviews Rule 404(b) admission for abuse of discretion)
United States v. Cotton, 823 F.3d 430 (government must identify permissible non‑propensity purpose and link evidence to a material issue)
United States v. Turner, 583 F.3d 1062 (prior drug dealings relevant to intent in conspiracy prosecutions)
Huddleston v. United States, 485 U.S. 681 (prior-act evidence is relevant if jury can reasonably conclude the act occurred and defendant was actor)
United States v. Emmanuel, 112 F.3d 977 (uncharged drug distribution evidence may be admissible)
United States v. Polk, 715 F.3d 238 (standard for reviewing sufficiency of evidence — view evidence in light most favorable to government)
United States v. Rolon-Ramos, 502 F.3d 750 (elements required to prove drug-conspiracy under 21 U.S.C. § 846)
United States v. Armijo, 834 F.2d 132 (prior drug use helps establish motive, intent, lack of accident)