United States v. Maurice Jones
2013 U.S. App. LEXIS 17728
| 8th Cir. | 2013Background
- Jones, a felon, was convicted of being a felon in possession of a firearm after trial evidence tied him to a gun found on a porch.
- Jones claimed he fabricated the Gino story to protect someone detained that night; he later admitted the story was made up.
- A jailcellmate, Elkins, testified that Jones confessed to possessing the gun; the government introduced a surveillance video of Jones and Elkins.
- Jones challenged Elkins’s credibility on cross-examination, including Elkins’s fraud convictions and motives; he sought to introduce a prior credibility finding by a magistrate judge.
- The district court restricted cross-examination and barred admission of the magistrate judge’s credibility finding; Jones moved for a new trial alleging a compromised verdict.
- The district court denied post-trial relief; the court of appeals affirmed the conviction and denial of relief.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| whether cross-examination was improperly restricted | Jones argues broader cross-examination would reveal bias/motive | Jones contends more questioning would affect credibility and Confrontation Clause rights | Harmless error; limits were not reversible |
| whether admission of the magistrate judge’s credibility finding was admissible | Jones seeks to prove credibility via the judge’s finding | Ruling that such findings are hearsay or inadmissible was proper | Error, if any, harmless beyond reasonable doubt |
| whether a new-trial should have been granted for a compromise verdict | Jones claims verdicts show compromise against weight of evidence | No clear demonstration of compromise; verdict supported by the record | No abuse of discretion; no clear compromise verdict |
Key Cases Cited
- United States v. Oaks, 606 F.3d 530 (8th Cir. 2010) (cross-examining on credibility can be cumulative)
- United States v. Cedeno, 644 F.3d 79 (2d Cir. 2011) (judicial credibility determinations; hearsay status discussed)
- United States v. Dawson, 434 F.3d 956 (7th Cir. 2006) (questions about third party credibility outside Rule 608 scope)
- United States v. Beck, 557 F.3d 619 (8th Cir. 2009) (duplicative cross-examination concerns; impeachment credibility)
- United States v. Wipf, 397 F.3d 677 (8th Cir. 2005) (allowed cross-examination; impeachment credibility considerations)
- United States v. Polk, 715 F.3d 238 (8th Cir. 2013) (extensive cross-examination may render further questioning non-determinative)
- United States v. Ramirez, 362 F.3d 521 (8th Cir. 2004) (standard for reviewing sufficiency of evidence; credibility determinations rely on jury)
- United States v. Perez, 663 F.3d 387 (8th Cir. 2011) (credibility determinations are largely within jury's discretion)
- Delaware v. Van Arsdall, 475 U.S. 673 (U.S. 1986) (harmless-error standard for Confrontation Clause violations)