United States v. David Sloan
401 F. App'x 66
6th Cir.2010Background
- Sloan, a felon, was convicted in a felon-in-possession case under 18 U.S.C. § 922(g).
- He sought a jury instruction on justification/necessity based on alleged threats around his cousin Myrick’s home in June 2003.
- The district court allowed evidence of threats but refused to admit psychiatric/psychological evidence and to give the requested instruction initially.
- Trial evidence included Sloan, Myrick, Sloan’s wife, Sloan’s father, and Kail; events described perils around the Kail property.
- The district court denied the justification instruction and instructed the jury to disregard any evidence of necessity or justification; Sloan moved for a mistrial, which was denied.
- Sloan was ultimately convicted and appealed, challenging the denial of the instruction and the denial of the mistrial motion.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| whether the district court properly denied the justification/necessity instruction | Sloan argues entitlement to instruction under Singleton factors | Government contends no prima facie case met the factors | No abuse of discretion; five factors not established by Sloan. |
| whether the district court’s denial of the mistrial motion was proper | Sloan claims instruction tainted trial, warranting mistrial | Government argues instruction was within court’s discretion to limit prejudice | No abuse of discretion; instruction to ignore evidence was permissible and not prejudicial. |
Key Cases Cited
- United States v. Ridner, 512 F.3d 846 (6th Cir. 2008) (establishes the five-factor test for justification/necessity in felon-in-possession cases)
- United States v. Singleton, 902 F.2d 471 (6th Cir. 1990) (early standard guiding the propriety of justification defense)
- United States v. Perez, 86 F.3d 735 (7th Cir. 1996) (illustrates rare applicability of necessity)
- United States v. Kemp, 546 F.3d 759 (6th Cir. 2008) (limits on breadth of defense of justification)
- United States v. Johnson, 416 F.3d 464 (6th Cir. 2005) (de novo review of prima facie finding for justification)
- United States v. Anderson, 605 F.3d 404 (6th Cir. 2010) (abuse-of-discretion standard for jury instructions)
- United States v. Martinez, 430 F.3d 317 (6th Cir. 2005) (abuse-of-discretion review for mistrial ruling)
- United States v. Faulkenberry, 614 F.3d 573 (6th Cir. 2010) (mistrial-review framework and prejudice analysis)