United States v. Eric Ladeaux, 61 F.4th 582

Eric Ladeaux was convicted by a jury of two counts of being a felon in possession and one count of possessing an unregistered sawed‑off shotgun after (1) a traffic stop identification and (2) arrest following a car chase where officers found a sawed‑off shotgun under the passenger seat where he had been sitting and ammunition at his feet.
The district court sentenced Ladeaux to 84 months’ imprisonment and three years’ supervised release.
Before trial the court (with the parties’ consent) entered Standing Orders limiting incarcerated defendants’ access to sealed/restricted discovery: review in designated prison areas, no copies or sharing with other inmates.
Mid‑trial Ladeaux requested a jury instruction on duress/coercion; the court reserved giving it unless he testified about coercion. He did not testify, so no instruction was given.
On appeal Ladeaux raised three challenges: (1) the Standing Orders denied his Sixth Amendment right to prepare for trial and violated Rule 16(d); (2) the court erred in refusing a duress/coercion instruction; and (3) insufficiency of evidence as to knowing possession of the shotgun.

Issue	Ladeaux’s Argument	Government’s Argument	Held
Standing Orders restricting access to sealed/restricted discovery	Orders deprived him of effective trial preparation and Rule 16(d) requires a “sufficient showing”/individualized inquiry before restricting discovery	Orders were entered with consent, satisfy Rule 16(d)’s "good cause," and protect safety/investigations; no objection below so review is for plain error	Reviewed for plain error; Rule 16(d) requires "good cause," not a separate "sufficient showing" standard; standing orders satisfy good cause; no plain error; affirmed
Request for duress/coercion jury instruction	Facebook video and messages show coercion/ imminent threat justifying an instruction	No evidence met the affirmative‑defense elements—particularly no showing there was no reasonable legal alternative; Ladeaux did not testify	De novo review: defendant failed to prove absence of legal alternatives; court properly refused instruction
Sufficiency of evidence of knowing possession of the shotgun	Argued he did not knowingly possess the sawed‑off shotgun	Proximity to the weapon, its placement under his seat with the stock toward him, ammunition at his feet, and his own statements support an inference of knowing possession	Reviewing the evidence in the light most favorable to the verdict, the evidence was sufficient; conviction affirmed

United States v. Pirani, 406 F.3d 543 (8th Cir. 2005) (plain‑error review applies to unpreserved arguments)
United States v. Smith, 4 F.4th 679 (8th Cir. 2021) (Rule 16(d)(1) requires "good cause"; standing orders consistent with rule)
United States v. Myles, 962 F.3d 384 (8th Cir. 2020) (elements of duress/coercion defense; legal‑alternative requirement)
United States v. Sharron, 986 F.3d 810 (8th Cir. 2021) (standard for entitlement to jury instruction on affirmative defenses)
United States v. Hensley, 982 F.3d 1147 (8th Cir. 2020) (standard for reviewing sufficiency of the evidence)
United States v. Grace, 893 F.3d 522 (8th Cir. 2018) (issues raised first in reply brief are waived)
United States v. Cordova, 806 F.3d 1085 (D.C. Cir. 2015) (discussing considerations for protective orders and good‑cause showing)
United States v. Wecht, 484 F.3d 194 (3d Cir. 2007) (weighing competing considerations when evaluating sealing/protective orders)
United States v. Dixon, 355 F. Supp. 3d 1 (D.D.C. 2019) (district courts have broad discretion; particularity needed depends on protective order type)