United States v. Stanley Weber, 987 F.3d 789

Stanley Weber, an Indian Health Service pediatrician, was indicted in South Dakota and Montana on multiple counts of aggravated sexual abuse and sexual abuse of minors; he was convicted in South Dakota on eight counts and sentenced to consecutive life and lengthy prison terms.
Law enforcement obtained a search warrant for Weber’s residence based on a 30-page affidavit and a four-page attachment, but the warrant itself did not identify specific items to be seized and described the property only as “evidence of a crime.”
The search yielded electronic devices, paper documents, and passport copies; Weber moved to suppress, arguing the warrant lacked Fourth Amendment particularity.
Before trial the government sought to admit prior sexual-assault testimony under Federal Rules of Evidence 413 and 414 from three witnesses (RFH, FSE, and GRC); GRC was unavailable at trial so the government offered prior testimony under Rule 804(b)(1).
The district court denied suppression, admitted the Rule 413/414 testimony (and GRC’s prior testimony), and the jury convicted; on appeal the court affirmed, finding any warrant error harmless and no abuse of discretion in evidentiary rulings.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Validity of search warrant / suppression	Warrant failed Fourth Amendment particularity; suppression required	Any defect cured by good-faith (Leon) or was harmless; seized evidence was cumulative/minimal	Doubtful the warrant met particularity, but any error was harmless beyond a reasonable doubt; denial affirmed
Admission of prior-act testimony under Rules 413/414	Testimony was unfairly prejudicial under Rule 403; multiple prior witnesses heightened prejudice	Testimony highly probative (similar modus operandi, rebutted conspiracy defense); limiting instruction mitigated prejudice	District court did not abuse discretion; admission proper
Admission of GRC’s prior testimony under Rule 804(b)(1)	Cold transcript hindered jury’s ability to assess credibility; should not admit	Prior testimony admissible when witness unavailable; better than losing evidence entirely	District court did not abuse discretion in admitting prior testimony

United States v. Leon, 468 U.S. 897 (1984) (establishes good-faith exception to exclusionary rule)
Chapman v. California, 386 U.S. 18 (1967) (harmless-error standard: harmless beyond a reasonable doubt)
Chambers v. Maroney, 399 U.S. 42 (1970) (applies harmless-error doctrine to Fourth Amendment errors)
United States v. Keys, 918 F.3d 982 (8th Cir. 2019) (admissibility under Rules 413/414 when prior acts share similarities)
United States v. Gabe, 237 F.3d 954 (8th Cir. 2001) (unfair prejudice defined as decision on improper basis)
United States v. LeCompte, 131 F.3d 767 (8th Cir. 1997) (Congressional judgment favors admitting prior sexual-offense evidence)
United States v. Crow Eagle, 705 F.3d 325 (8th Cir. 2013) (appellate deference to district court’s Rule 403 balancing)
United States v. Hollow Horn, 523 F.3d 882 (8th Cir. 2008) (limiting instruction reduces prejudice from propensity evidence)
United States v. Szczerba, 897 F.3d 929 (8th Cir. 2018) (standard of review for suppression rulings)