United States v. Casteel
2011 U.S. App. LEXIS 24973
| 8th Cir. | 2011Background
- Casteel and Tiran were tried together on multiple counts including carjacking and weapons charges; district court denied severance but severed some weapons counts from robbery counts.
- Casteel challenged severance and admission of prior-acts evidence; the jury convicted both defendants on all counts.
- Eitzen, an elderly victim, was held at gunpoint during a lengthy robbery at her rural Iowa home; the car was stolen from the driveway.
- Coins from Eitzen's late husband's collection linked to the robbery; searches revealed coins in the Casteels' car and residence.
- Tiran attempted to have Eitzen killed to prevent testimony; letters and conversations were admitted as evidence against him but not against Casteel for those counts.
- District court admitted coin-sales evidence on Robbery/Identity theory, over defense objections, as probative of familiarity with the crime scene.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether severance was abused by denying joint trial | Casteel argues severance was required due to prejudicial evidence of Tiran | Casteel contends jury could not compartmentalize the evidence | No abuse; careful instructions mitigated prejudice |
| Sufficiency of evidence for carjacking presence | Eitzen's car taken from her presence, satisfying §2119 | No proof car was within presence or reach | Reasonable jury could find car was taken from Eitzen's reach |
| Sufficiency of evidence for intent to kill/seriously harm | Casteel intended serious harm to take car | Evidence insufficient to show intent to kill/serious harm | Evidence adequate to support intent requirement under §2119 |
| Admission of coin-sale and other-acts evidence | Coin sales properly probative of identity and familiarity | Prejudicial acts evidence risked confusion | No abuse; admissible as non-propensity evidence relevant to robbers' identity and method |
| New trial judgment based on Rule 33 and evidentiary rulings | Error-free trial; no miscarriage of justice | Evidentiary rulings harmed defense | No reversible error; affirm conviction |
Key Cases Cited
- United States v. Payton, 636 F.3d 1027 (8th Cir.2011) (standard for severance abuse requires clear prejudice)
- United States v. Al-Esawi, 560 F.3d 888 (8th Cir.2009) (presumption in favor of joinder; prejudice must be severe)
- United States v. Lewis, 557 F.3d 601 (8th Cir.2009) (joinder presumptively efficient; need for compartmentalization and instructions)
- Zafiro v. United States, 506 U.S. 534 (1993) (protects use of jury instructions to cure spillover of evidence)