United States v. Teague
2011 U.S. App. LEXIS 15552
8th Cir.2011Background
- Teague, a privileged NSLDS user, was identified as having accessed Barack Obama's student loan records.
- The government presented a log showing Obama search at 5:55 a.m. and a Marc Martin search 28 minutes later from Teague's workplace IP.
- Teague admitted performing the Marc Martin search; she denied conducting the Obama search.
- Evidence showed no inactivity timeout between the Obama and Marc Martin searches, suggesting a continuous session.
- Co-worker testimony and Teague's prior statements undermined her credibility regarding the Obama search.
- Teague sought a court-appointed computer expert under 18 U.S.C. § 3006A(e), which the district court denied without prejudice.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Sufficiency of evidence for identity | Teague argues the government failed to prove she conducted the Obama search. | The government contends circumstantial evidence plus Teague's admissions establish guilt beyond reasonable doubt. | Evidence sufficient to support conviction. |
| Authority to deny expert funds | Teague contends the district court abused its discretion by denying funding and prejudicing her defense. | The government argues the request lacked demonstrated necessity and was not a fishing expedition. | District court did not abuse discretion; denial affirmed. |
Key Cases Cited
- United States v. Piwowar, 492 F.3d 953 (8th Cir. 2007) (standard for sufficiency of circumstantial evidence favors government)
- United States v. McCloud, 590 F.3d 560 (8th Cir. 2009) (strict standard: must view in government's favor when reviewing sufficiency)
- United States v. Hayes, 391 F.3d 958 (8th Cir. 2004) (jury's verdict not to be lightly overturned)
- United States v. Mentzos, 462 F.3d 830 (8th Cir. 2006) (abuse-of-discretion standard for Criminal Justice Act funding)
- United States v. Thurmon, 413 F.3d 752 (8th Cir. 2005) (necessity for expert; not a fishing expedition)
- United States v. Schultz, 431 F.2d 907 (8th Cir. 1970) (underlying facts must reasonably suggest benefit from further exploration)
- United States v. Ladoucer, 573 F.3d 628 (8th Cir. 2009) (expert unnecessary where theory speculative)
- United States v. Janis, 831 F.2d 773 (8th Cir. 1987) (denying funding upheld when underlying facts do not support theory)
- United States v. Davis, 471 F.3d 938 (8th Cir. 2006) (jury credibility assessment within the province of the jury)
- United States v. McGuire, 45 F.3d 1177 (8th Cir. 1995) (requirement to prove guilt beyond reasonable doubt; multiple narratives exist)