99 F.4th 432
8th Cir.2024Background
- Tyrone Cameron was convicted by a jury of being a felon in possession of ammunition and sentenced to 120 months in prison.
- The government connected Cameron to a shooting at the Hickman Flats apartments through circumstantial evidence, including surveillance footage, eyewitness testimony from his girlfriend, and clothing found at her home.
- Cameron argued (on appeal) that the evidence was insufficient, his Second Amendment rights were violated post-Bruen, his prior convictions should not have been admitted, and the prosecutor committed misconduct in closing arguments.
- The district court had admitted evidence of Cameron’s prior felony convictions to show knowledge and rebut his claimed lack of violent history.
- The appellate court affirmed the conviction, addressing each claim and finding no grounds for reversal or plain error.
Issues
| Issue | Cameron's Argument | Government's Argument | Held |
|---|---|---|---|
| Sufficiency of evidence | Insufficient evidence connected him to ammo possession | Ample circumstantial evidence linked Cameron to the shooting and possession | Evidence sufficient to affirm |
| 2nd Amendment challenge to § 922(g)(1) | Statute is unconstitutional as applied post-Bruen | Bruen and circuit precedent uphold the felon prohibition | No plain error; law is constitutional |
| Admission of prior convictions | Irrelevant, prejudicial, and too remote in time | Probative for knowledge, intent, and rebutting specific claims | Admission proper; no abuse of discretion |
| Prosecutorial misconduct in closings | Government improperly accused him of lying | Remarks were based on evidence and permissible argument | No misconduct; no prejudice |
Key Cases Cited
- United States v. Obi, 25 F.4th 574 (8th Cir. 2022) (standard for reviewing sufficiency of the evidence)
- United States v. Seals, 915 F.3d 1203 (8th Cir. 2019) (circumstantial evidence sufficient for conviction)
- United States v. Everett, 977 F.3d 679 (8th Cir. 2020) (forensic evidence not required for firearms conviction)
- United States v. Jackson, 69 F.4th 495 (8th Cir. 2023) (Bruen does not invalidate felon-in-possession laws)
- United States v. Cunningham, 70 F.4th 502 (8th Cir. 2023) (affirming constitutionality of felon-in-possession laws after Bruen)
- United States v. Halk, 634 F.3d 482 (8th Cir. 2011) (admissibility of prior bad acts/evidence)
- United States v. Frokjer, 415 F.3d 865 (8th Cir. 2005) (prosecutor’s commentary on credibility permissible if based on evidence)