United States v. Derek Benedict
855 F.3d 880
| 8th Cir. | 2017Background
- Derek Benedict and Lyle Carpenter were convicted after a joint jury trial for conspiracy and multiple burglaries (2009–2013) targeting drug stores, ATMs, safes, and registers across Minnesota and Iowa; several coconspirators pleaded guilty and testified against them.
- Carpenter specialized in drilling safes/ATMs; Benedict acted as driver/lookout and used burglary proceeds (purchased an Infiniti).
- Physical and forensic evidence included a glove with Carpenter-linked DNA and footage of Carpenter’s arrest; a cooperating coconspirator recorded conversations implicating both defendants.
- Both defendants were sentenced as career offenders under U.S.S.G. § 4B1.1 (2014); Carpenter received 210 months + restitution, Benedict 150 months + restitution.
- On appeal they challenged: denial of severance (Benedict), exclusion of expert testimony (Benedict), sufficiency of evidence (Benedict), restitution under the MVRA (Carpenter), acceptance of defense stipulation, and career-offender enhancements for both.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Severance (Benedict) | Joint trial proper; government: evidence supported joinder. | Benedict: evidence mostly against Carpenter (DNA, arrest video) prejudiced him. | Denied; no abuse of discretion—limiting instructions and properly joined charges avoided severe prejudice. |
| Exclusion of expert testimony (Dr. Neuschatz) | Benedict: expert on accomplice testimony bias was necessary to counter coconspirator testimony. | Court: untimely and inadequate Rule 16 disclosures; testimony intruded on credibility determinations. | Affirmed exclusion for failure to disclose and because testimony impermissibly addressed witness credibility. |
| Sufficiency of evidence (Benedict) | Benedict: coconspirator testimony insufficient/corroboration lacking; evidence showed intermittent nonparticipation. | Government: multiple coconspirators corroborated Benedict’s participation; additional documentary evidence (car title). | Convictions upheld; coconspirator testimony credible and corroborated, supporting conspiracy convictions. |
| Restitution / MVRA & career-offender status (Carpenter & Benedict) | Carpenter: corporations are not "persons" under MVRA; some store-losses unrelated to federal offenses; both: prior burglary convictions not "crimes of violence." | Government: Dictionary Act includes corporations; stores were directly harmed by charged scheme; burglary offenses present serious risk of physical injury and fit residual clause. | Affirmed: corporations qualify as victims under MVRA; restitution to stores proper; prior burglary convictions qualify as crimes of violence under the § 4B1.2 residual clause (2014), so career-offender designations stand. |
Key Cases Cited
- United States v. Delpit, 94 F.3d 1134 (8th Cir. 1996) (strong presumption favoring joint trials)
- United States v. Dierling, 131 F.3d 722 (8th Cir. 1997) (joint trial prejudice standard)
- United States v. Martin, 777 F.3d 984 (8th Cir. 2015) (defendant bound by unobjected-to stipulation; tolerances for Rule 11-style inquiry)
- Nichols v. Am. Nat'l Ins. Co., 154 F.3d 875 (8th Cir. 1998) (expert testimony cannot improperly comment on witness credibility)
- United States v. Holmes, 670 F.3d 586 (4th Cir. 2012) (upholding exclusion of expert testimony for Rule 16 disclosure failures)
- United States v. Senty-Haugen, 449 F.3d 862 (8th Cir. 2006) (MVRA victim analysis)
- United States v. Cantrell, 530 F.3d 684 (8th Cir. 2008) (burglary-related risk of violent confrontation supports classification as crime of violence)
- United States v. Stymiest, 581 F.3d 759 (8th Cir. 2009) (generic burglary as crime of violence under guideline residual clause)
- United States v. McArthur, 850 F.3d 925 (8th Cir. 2017) (Minnesota third-degree burglary broader than generic burglary for ACCA enumerated clause analysis)