United States v. William Bell, 819 F.3d 310

In 2011 at USP Terre Haute, inmates William Bell and Lenard Dixon were cellmates; surveillance showed Bell enter victim Brian Pendelton’s cell and leave shortly thereafter shirtless and carrying a bundle. Pendelton soon collapsed from a stab wound to his neck and later died.
Video showed Dixon sitting outside their cell while Bell was inside Pendelton’s, later leaving with clothing, passing the injured Pendelton, going to another cell briefly, then placing a bundle in a day-room trash can; a makeshift sharpened metal rod and bloody clothing (including an item with Bell’s name) were recovered from that trash can.
Bell was charged with first-degree (premeditated) murder; Dixon was charged as an accessory after the fact. Both were tried jointly and convicted; Bell received life, Dixon 156 months consecutive.
Bell moved to exclude testimony recounting an alleged threatening statement he made in a separate disciplinary incident; he argued the BOP’s failure to preserve an illegible scanned witness statement and surveillance video violated due process. The district court admitted the testimony; the court found no bad faith in the loss and that the lost evidence was not constitutionally material.
Dixon moved to prevent leg restraints at trial. The district court ordered Dixon’s legs restrained (hidden by skirted tables and other precautions) based on his violent criminal and disciplinary history; the court found a special need for minimal restraints.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Admissibility of Morris’s testimony about Bell’s alleged threatening statement	Government: testimony admissible; loss of scanned statement and video not bad faith and not material	Bell: BOP’s failure to preserve legible statement and video violated due process; exclude Morris	Court: No bad faith; Davis testified; video not clearly exculpatory; testimony admitted
Sufficiency of evidence of premeditation for Bell	Government: circumstantial evidence (weapon carried, quick efficient attack, calm behavior, coordination with Dixon) shows deliberation	Bell: evidence too thin to prove premeditation	Court: Evidence sufficient for a rational jury to find premeditation beyond reasonable doubt
Leg shackling of Dixon during trial	Government: restraints necessary for courtroom security given Dixon’s violent and weapons history	Dixon: no history of courtroom misconduct or escape; shackling prejudicial	Court: No abuse of discretion; special need shown; precautions minimized jury awareness
Sufficiency of evidence for accessory-after-the-fact (Dixon)	Government: video and conduct show Dixon knowingly disposed of bloody clothing/weapon and lied to investigators, supporting intent to hinder	Dixon: no direct proof of intent, motive, or complicity	Court: Circumstantial evidence (choreography, disposal of bundle, false statements) sufficient to sustain conviction

Arizona v. Youngblood, 488 U.S. 51 (1988) (government must act in bad faith to violate due process by failing to preserve potentially useful evidence)
California v. Trombetta, 467 U.S. 479 (1984) (lost evidence is material only if defendant cannot obtain comparable evidence)
United States v. Valenzuela-Bernal, 458 U.S. 858 (1982) (due-process claim for lost evidence requires bad faith and materiality analysis)
Deck v. Missouri, 544 U.S. 622 (2005) (restraints in court implicate presumption of innocence and require special need)
Jackson v. Virginia, 443 U.S. 307 (1979) (standard for reviewing sufficiency of evidence: whether any rational trier of fact could find guilt beyond reasonable doubt)
Fisher v. United States, 328 U.S. 463 (1946) (premeditation requires appreciable time for reflection)
United States v. Begay, 673 F.3d 1038 (9th Cir. 2012) (carrying weapon to scene is strong evidence of premeditation)
United States v. Brown, 518 F.2d 821 (7th Cir. 1975) (deliberation and premeditation involve prior design)
United States v. Van Sach, 458 F.3d 694 (7th Cir. 2006) (review of shackling decision for abuse of discretion)
United States v. Cooper, 591 F.3d 582 (7th Cir. 2010) (restraints can prejudice jury; courts must justify special need)