United States v. Troy Lawrence, 682 F. App'x 525

Troy Alan Lawrence was convicted by a jury of (1) conspiracy to distribute and possession with intent to distribute methamphetamine (21 U.S.C. §§ 841, 846) and (2) attempted obstruction of justice; district court sentenced him to 262 months’ imprisonment.
Prosecution evidence: testimony that Martin Lawrence supplied methamphetamine; witnesses (Ridler, Rackley, Maskewit) placed Troy with Martin during drug transactions and described repackaging and distribution activity.
Law enforcement recovered multiple individually wrapped methamphetamine packets and distribution-level quantities and paraphernalia from Lawrence’s vehicle on two occasions (including a 23‑gram 99% pure seizure, scale, gloves, plastic bags); cash was found on his person.
Evidence linked Lawrence to the vehicle and its contents (he admitted ownership at accident scene; tools and witnesses showed dominion/control; girlfriend Maskewit testified she delivered drugs and collected proceeds for him).
Lawrence moved for acquittal under Rule 29, arguing insufficient evidence (including attacking Maskewit’s credibility); he also challenged the substantive reasonableness of his sentence on appeal.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Sufficiency of evidence for conspiracy to distribute methamphetamine	Lawrence: evidence was insufficient to prove he knew of and joined a conspiracy	Government: circumstantial and direct witness testimony, plus distribution‑level seizures and packaging, show tacit agreement and participation	Affirmed — evidence sufficient for conspiracy conviction
Sufficiency of evidence for possession with intent to distribute	Lawrence: he did not possess or intend to distribute; vehicle not registered to him undermines constructive possession	Government: possession (actual or constructive) supported by dominion/control, quantity/purity, packaging, paraphernalia, prior sales, and cash to infer intent	Affirmed — evidence sufficient for possession with intent to distribute
Credibility attack on key witness (Maskewit)	Lawrence: Maskewit’s long-term methamphetamine use made her testimony unreliable	Government: credibility is for the jury; jury heard addiction evidence and still credited her testimony	Affirmed — credibility determinations upheld on appeal
Substantive reasonableness of sentence	Lawrence: district court overemphasized criminal history, ignored other § 3553(a) factors, resulting in an unreasonable sentence	Government: court considered § 3553(a) factors and permissibly weighted recidivism heavily	Affirmed — sentence not substantively unreasonable; no abuse of discretion

United States v. Keys, 721 F.3d 512 (8th Cir. 2013) (standard for sufficiency review; jury credibility deference)
United States v. Thompson, 686 F.3d 575 (8th Cir. 2012) (elements of possession with intent to distribute)
United States v. Cabrera, 116 F.3d 1243 (8th Cir. 1997) (circumstantial evidence can establish conspiracy; tacit understanding suffices)
United States v. Moya, 690 F.3d 944 (8th Cir. 2012) (government may prove conspiracy by direct or circumstantial evidence)
United States v. Fetters, 698 F.3d 653 (8th Cir. 2012) (drug quantity, paraphernalia, prior sales, and cash support inference of intent to distribute)
United States v. Serrano‑Lopez, 366 F.3d 628 (8th Cir. 2004) (constructive possession can be established by dominion and control)
United States v. Diaz‑Pellegaud, 666 F.3d 492 (8th Cir. 2012) (standard for substantive‑reasonableness review)
United States v. Wilcox, 666 F.3d 1154 (8th Cir. 2012) (wide latitude for sentencing courts in weighing § 3553(a) factors)
United States v. Coleman, 635 F.3d 380 (8th Cir. 2011) (district court may vary from Guidelines based on policy disagreement)
United States v. Keating, 579 F.3d 891 (8th Cir. 2009) (presumption that court considered argued § 3553(a) factors)
United States v. Feemster, 572 F.3d 455 (8th Cir. 2009) (en banc) (rare reversal for substantive‑reasonableness errors)