716 F.3d 491
8th Cir.2013Background
- St. John, Standing Rock Sioux Tribe member, was charged with domestic assault by a habitual offender under 18 U.S.C. § 117.
- The government presented White Bull’s injuries and her report to authorities after the July 2011 incident.
- St. John argued the government failed to prove cohabitation as intimate partners.
- The jury was instructed on the four required elements including cohabitation and that the offense occurred in Indian country.
- The district court denied motions for acquittal, and the jury convicted; sentence: 24 months imprisonment.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Was there sufficient evidence that St. John and White Bull were cohabiting as intimate partners? | St. John argues no cohabitation. | Government argues evidence showed dating since 2002 and cohabitation. | Yes; evidence viewed in the light most favorable supported cohabitation. |
Key Cases Cited
- United States v. Clark, 668 F.3d 568 (8th Cir. 2012) (sufficiency review; credibility not weighed by reviewing court)
- United States v. Wiest, 596 F.3d 906 (8th Cir. 2010) (jury credibility resolves conflicts; appellate deference on facts)