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United States v. David Griffith
2015 U.S. App. LEXIS 8607
| 8th Cir. | 2015
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Background

  • Griffith, a felon, was found with shotgun parts in the car he drove.
  • Jury convicted Griffith under 18 U.S.C. § 922(g) for unlawful firearm possession.
  • Burglary occurred on June 5, 2013; a neighbor identified Griffith and the car involved.
  • Police traced the car via license plate and stopped Griffith about 20 minutes after the burglary.
  • A shotgun receiver and TV were recovered from the car and later seized under a warrant.
  • District court instructed that brief possession can support a conviction, and Griffith appeals on both possession instructions and sufficiency of knowledge evidence.

Issues

Issue Plaintiff's Argument Defendant's Argument Held
Whether the evidence shows Griffith knowingly possessed the firearm. Griffith argues the government failed to prove knowledge of the gun. Griffith contends mere proximity is insufficient; knowledge was not shown. Sufficient evidence supports knowledge; conviction affirmed.
Whether the possession instruction improperly lowered the burden by allowing brief possession as basis for conviction. Griffith claims the instruction reduced the required certainty. Government invites proper consideration of possession and knowledge in context. No reversible error; instructions were proper in context.

Key Cases Cited

  • United States v. Lewis, 593 F.3d 765 (8th Cir. 2010) (district-court instruction discretion in crafting jury instructions)
  • United States v. Stymiest, 581 F.3d 759 (8th Cir. 2009) (instructional-error review requires accurate law and effect on substantial rights)
  • United States v. Patterson, 684 F.3d 794 (8th Cir. 2012) (juror should follow comprehensive instructions; view as whole)
  • United States v. Chatmon, 742 F.3d 350 (8th Cir. 2014) (sufficiency of evidence for felon-in-possession; constructive possession requires nexus)
  • United States v. Serrano-Lopez, 366 F.3d 628 (8th Cir. 2004) (sufficiency standard; evidence can support guilty verdict under reasonable-inference)
Read the full case

Case Details

Case Name: United States v. David Griffith
Court Name: Court of Appeals for the Eighth Circuit
Date Published: May 26, 2015
Citation: 2015 U.S. App. LEXIS 8607
Docket Number: 14-1976
Court Abbreviation: 8th Cir.