United States v. Marcus Eason
2016 U.S. App. LEXIS 12916
| 8th Cir. | 2016Background
- On June 16, 2012, North Little Rock police stopped Marcus Eason after a 911 domestic disturbance report and recovered a .45-caliber pistol and two spent .45 casings near where Eason had been walking. Eason was charged under 18 U.S.C. §§ 922(g)(1) and 924(e)(1).
- While on pretrial release, on April 9, 2013, Eason was present during a separate incident at Hiawatha Williams’s home where a .380 pistol was fired; investigators later found a 9mm bullet and casing in Williams’s bedroom. A superseding indictment added Count 2: felon in possession of ammunition.
- A jury convicted Eason on both counts. At sentencing the district court applied the Armed Career Criminal Act (ACCA), finding at least three qualifying prior convictions and imposed a 300-month sentence (Guidelines range 262–327 months).
- At trial the court excluded a dash-cam video from being shown to the jury (allowed limited impeachment questioning but not playback) and excluded defense photographs as a discovery-sanction under Fed. R. Crim. P. 16(b)(1)(A).
- Eason appealed challenging (1) exclusion of the dash-cam video and photographs, (2) sufficiency of the evidence on Count 2 (ammunition), and (3) the ACCA enhancement. The Eighth Circuit affirmed the convictions but vacated the ACCA sentence and remanded for resentencing.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Exclusion of dash-cam video at trial | Eason: video should be shown to jury to impeach officer and display scene conditions | Government: video need not be admitted; later argued Rule 16 reciprocal discovery violation | Court: no abuse of discretion; video could be used for questioning but not played; nondisclosure did not materially affect substantial rights |
| Exclusion of defense photographs | Eason: photos relevant and jurors requested scene view; exclusion was too harsh | Government: defense violated Rule 16 by not producing photos pretrial | Court: exclusion proper under Rule 16; even if error, no showing of prejudice to verdict |
| Sufficiency of evidence for Count 2 (ammunition) | Eason: government failed to prove he knowingly possessed the 9mm ammunition | Government: eyewitness testimony, 911 call, and spent casings supported a reasonable inference of possession | Court: evidence sufficient; reasonable jury could find knowing possession beyond a reasonable doubt |
| ACCA enhancement validity | Eason: residual clause is unconstitutionally vague; his priors do not qualify under force clause | Government: argued Eason had three qualifying prior convictions (defendant conceded one drug predicate) | Court: Johnson voided residual clause; Arkansas robbery and domestic-battery convictions do not categorically qualify under the force clause based on the record; ACCA enhancement unsupported — sentence vacated and remanded |
Key Cases Cited
- Johnson v. United States, 559 U.S. 133 (2010) ("physical force" means violent force for ACCA-type definitions)
- Taylor v. United States, 495 U.S. 575 (1990) (categorical approach for determining predicate offenses)
- Medearis v. United States, 380 F.3d 1049 (8th Cir. 2004) (Rule 16 does not require pretrial disclosure of impeachment evidence)
- Shockley v. United States, 816 F.3d 1058 (8th Cir. 2016) (de novo review whether a prior conviction qualifies under the ACCA)
- United States v. Sawyer, 588 F.3d 548 (8th Cir. 2009) (pre-Johnson holding treating Arkansas robbery as crime of violence under Guidelines)
- Schaffer v. United States, 818 F.3d 796 (8th Cir. 2016) (definition of "physical force" as violent force in ACCA analysis)
- Picardi v. United States, 739 F.3d 1118 (8th Cir. 2014) (reversal for evidentiary error requires showing of effect on substantial rights)