United States v. Jean-Guerrier
2012 U.S. App. LEXIS 1966
8th Cir.2012Background
- Jean-Guerrier, a Haitian national, was convicted of possessing with intent to distribute over 100 kilograms of marijuana and conspiracy with Fraser.
- A Missouri stop of a semi-truck carrying a stolen trailer revealed approximately 1000 pounds of marijuana; Fraser drove, Jean-Guerrier slept in the sleeper berth.
- A grand jury charged both men; Fraser pled guilty and agreed to assist the government; Jean-Guerrier demanded a jury trial on the possession count.
- Before trial, the government sought to introduce 404(b) evidence through Fraser about prior trips transporting marijuana along the same route; the district court allowed it, excluding only trips with Fraser not involving Jean-Guerrier.
- During trial, the government questioned Jean-Guerrier about his accent; a court security officer testified that Jean-Guerrier spoke without an accent during recesses; Bates testified as a rebuttal witness.
- Jean-Guerrier was convicted and sentenced to 97 months; he appeals, arguing the district court abused its discretion by admitting Bates’s rebuttal testimony and the Fraser 404(b) evidence, and moves for a new trial.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Bates’s rebuttal testimony was admissible | Jean-Guerrier argues Bates’s testimony was improper impeachment | State may use rebuttal to explain or counter evidence | No plain error; rebuttal admissible |
| Whether Fraser’s prior-trip testimony fell within Rule 404(b) | Fraser’s trips with others were improper character evidence against Jean-Guerrier | Evidence relevant to knowledge/plan and not used to prove character | Not error; testimony admissible as non-404(b) evidence supporting knowledge |
| Whether the district court’s evidentiary rulings warrant reversal under plain error standard | Errors affected substantial rights | No plain error evident | Rulings affirmed; no reversal |
Key Cases Cited
- United States v. Harris, 557 F.3d 938 (8th Cir. 2009) (rebuttal evidence standards; relevance)
- United States v. White Bull, 646 F.3d 1082 (8th Cir. 2011) (plain error review; preservation concerns)
- United States v. Halk, 634 F.3d 482 (8th Cir. 2011) (rule 404(b) limitations; knowledge/plan purposes)
- United States v. Riddle, 193 F.3d 995 (8th Cir. 1999) (extrinsic evidence and Rule 608/613 distinctions)
- Bennett v. Nucor Corp., 656 F.3d 802 (8th Cir. 2011) (deference to Rule 403 weighing; on-the-spot balancing)