United States v. Clayton
787 F.3d 929
| 8th Cir. | 2015Background
- Clayton robbed Citizens State Bank in Fort Dodge, Iowa, with accomplice Anderson; Clayton was convicted and sentenced to 129 months.
- Anderson testified that Clayton solicited a ride and carried profits from the bank to Omaha; phone records and calls supported the timeline.
- Money from the robbery included bait bills later recovered at a third party’s home; Clayton and Anderson split cash in Omaha.
- Clayton faced a prior Iowa conviction for third-degree theft involving violent threats and a bomb threat; the district court considered this for sentencing.
- The district court admitted Iowa trial minutes and Barbara Gordon’s testimony to prove violent threats in a separate robbery (Mr. Money).
- Clayton challenged coaching of witnesses and the use of minutes at sentencing; the court upheld the conviction and enhanced sentence.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether improper coaching violated due process | Clayton | Clayton | No reversible prejudice; no due-process violation. |
| Sufficiency of the evidence to convict | Clayton contends insufficient evidence | United States | Evidence, viewed most favorably to the government, supports conviction. |
| Verdict against the weight of the evidence | Clayton argues credibility issues | United States | Verdict not against the weight of the evidence; district court acted within discretion. |
| Use of Iowa minutes to support sentence | Clayton challenges reliance on minutes for sentence | United States | Minutes admissible for sentencing when corroborated by other evidence; not the sole basis. |
Key Cases Cited
- United States v. Hunter, 770 F.3d 740 (8th Cir. 2014) (prosecutorial-misconduct standard for improper coaching claims)
- United States v. New, 491 F.3d 369 (8th Cir. 2007) (prejudice requirement for due-process impact)
- United States v. Nambo-Barajas, 338 F.3d 956 (8th Cir. 2003) (coaching evidence examined in cross-examination context)
- United States v. Martin, 777 F.3d 984 (8th Cir. 2015) (standard for evaluating sufficiency of evidence)
- United States v. Chavez, 230 F.3d 1089 (8th Cir. 2000) (credibility determinations within jury’s province)
- United States v. Funchess, 422 F.3d 698 (8th Cir. 2005) (credibility and weight of witness testimony)
- United States v. Teague, 646 F.3d 1119 (8th Cir. 2011) (standard for evaluating circumstantial evidence and inferences)
- United States v. Mohamed, 757 F.3d 757 (8th Cir. 2014) (sentencing information admissibility and reliability)
- United States v. Garcia, 774 F.3d 472 (8th Cir. 2014) (district court discretion in sentencing and evidence sources)
- United States v. Atkins, 250 F.3d 1203 (8th Cir. 2001) (reliability and corroboration in sentencing evidence)
- United States v. Cover, 703 F.3d 477 (8th Cir. 2013) (treatment of Alford pleas and predicate offenses)