United States v. Brandon Buckles
666 F. App'x 670
| 9th Cir. | 2016Background
- Defendant Brandon Buckles was convicted of one count of sexual abuse (18 U.S.C. §§ 1153(a), 2242) and one count of making a false statement to a federal officer (18 U.S.C. § 1001(a)(2)).
- At trial the government presented compelling DNA evidence tying Buckles to the sexual-abuse charge.
- Buckles sought to admit evidence of a prior sexual relationship with the victim; the district court excluded that evidence.
- Buckles did not raise a Sixth Amendment challenge to the exclusion at trial; on appeal he argued the exclusion violated his right to present a defense.
- Buckles also challenged the sufficiency of the evidence supporting the materiality element of his § 1001 conviction.
- The Ninth Circuit reviewed the exclusion of evidence for abuse of discretion and reviewed sufficiency of the evidence de novo; it affirmed both convictions.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Exclusion of prior sexual-relationship evidence | Buckles: excluding the relationship evidence violated his Sixth Amendment right to present a defense | Government: evidence was properly excluded after balancing probative value and prejudice | Court: No Sixth Amendment violation; exclusion not plain error and trial court properly balanced factors |
| Failure to preserve Sixth Amendment claim | Buckles: appellate review should nonetheless find error | Government: Buckles failed to raise the claim at trial; plain-error standard applies | Court: Buckles failed to show plain error; claim rejected |
| Sufficiency of evidence for sexual-abuse conviction | Buckles: conviction not supported by substantial evidence | Government: DNA and other evidence supported conviction | Court: Viewing evidence in government’s favor, a rational juror could convict; conviction stands |
| Materiality of false statement (18 U.S.C. § 1001) | Buckles: his false statements were not material | Government: statements had propensity to influence investigation and affected agent’s actions | Court: Statements were material; substantial evidence supported the § 1001 conviction |
Key Cases Cited
- Wood v. Alaska, 957 F.2d 1544 (9th Cir. 1992) (framework for admitting defense evidence and balancing probative value against prejudice)
- Pino‑Noriega v. United States, 189 F.3d 1089 (9th Cir. 1999) (plain‑error review when defendant fails to preserve trial objection)
- Norwood v. United States, 603 F.3d 1063 (9th Cir. 2010) (standard for reviewing sufficiency of the evidence)
- Rios v. United States, 449 F.3d 1009 (9th Cir. 2006) (use of the same sufficiency-of-the-evidence standard)
- Valensia v. United States, 299 F.3d 1068 (9th Cir. 2002) (compelling forensic evidence can cure prejudice from excluded testimony)
- Vaughn v. United States, 797 F.2d 1485 (9th Cir. 1986) (materiality under § 1001: statement need only have propensity to influence agency action)