United States v. Douglas Meeks
742 F.3d 838
8th Cir.2014Background
- Meeks was convicted of conspiracy to distribute at least 50 grams of cocaine base and distribution of at least 5 grams; district court imposed life on the conspiracy count and 360 months on the distribution count, affirmed on appeal.
- During trial, government witness Cardale Smith testified about a controlled buy; he admitted past drug activity, cooperation motives, and bias against Meeks, and his testimony was supplemented by Monique Nicholson.
- Smith’s testimony, along with Nicholson’s corroboration, supported a conviction for the charged offenses.
- After trial, Smith pled guilty to related drug offenses; Meeks moved for a new trial under Rule 33(b) based on newly discovered perjury by Smith.
- The district court denied the motion, concluding the new impeachment evidence was unlikely to yield an acquittal; the court noted overwhelming trial evidence.
- On appeal, the Eighth Circuit affirmed, applying the rigorous abuse-of-discretion standard and concluding the new evidence was not material and would not likely result in acquittal.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the Rule 33(b) denial was an abuse of discretion | Meeks argues newly discovered perjury could yield acquittal. | Government contends evidence would not be material or likely to change the verdict. | No abuse; evidence not material and unlikely to yield acquittal. |
Key Cases Cited
- United States v. Baker, 479 F.3d 574 (8th Cir. 2007) (Rule 33(b) motions are disfavored and require clear abuse of discretion)
- United States v. Rubashkin, 655 F.3d 849 (8th Cir. 2011) (framework for newly discovered-evidence standards)
- United States v. Johnson, 450 F.3d 366 (8th Cir. 2006) (impeachment evidence alone not sufficient for acquittal)
- United States v. Hollowhorn, 523 F.3d 882 (8th Cir. 2008) (impeachment allegations of coached testimony do not guarantee relief)
- United States v. Placensia, 352 F.3d 1157 (8th Cir. 2003) ( miscarriage of justice standard for new trials)
- United States v. Dogskin, 265 F.3d 682 (8th Cir. 2001) (newly discovered evidence must be more than impeachment)