United States v. Woodmore, 135 F.4th 861

Early Woodmore, along with his brother Calvin, led a multi-member methamphetamine distribution ring in eastern Oklahoma, supplied from California, with at least 20–30 pounds shipped.
After arrests in 2019, a federal grand jury charged Early on several counts, including conspiracy to distribute large quantities of methamphetamine (actual) and money laundering.
At trial in April 2022, Early and Calvin were jointly tried and convicted on all counts; Early received a life sentence for the most serious charges.
Early's appeal followed Calvin and Amber Woodmore’s earlier, unsuccessful appeals regarding their roles in the conspiracy.
Early's appeal to the Tenth Circuit challenged three rulings: the district court’s response to a trial custody dispute (alleging judicial bias), a jury instruction concerning attorney-witness meetings, and the lack of a jury definition for "methamphetamine (actual)."

Issue	Plaintiff's Argument	Defendant's Argument	Held
Judicial bias in resolving custody dispute	Court's intervention in a family custody issue at trial showed actual or apparent bias, violating due process/recusal law	District court properly managed courtroom order to protect witness and maintain proceedings	No error; court acted reasonably within its role, no appearance of bias
Attorney-witness interview instruction	Instruction wrongly stated attorneys had a "right" to meet witnesses, undermining witness credibility assessments	Instruction was proper, did not mislead jury, and defense could challenge witness bias	No reversible error; objection effectively waived and instruction proper
Definition of "methamphetamine (actual)"	Jury was not told how to determine "actual" quantity, risking confusion and improper conviction/penalty	Ordinary meaning, trial evidence made term clear, and proposed definition unnecessary	No abuse of discretion; instruction adequate, no prejudice to defendant
Jury finding on 50g "actual" meth required	Absence of explicit jury finding under Apprendi should vacate life sentence on Count Two	Evidence and instructions allowed jury to find 50g+ of actual meth; statutory basis clear	No error; jury necessarily found required facts beyond reasonable doubt

Marshall v. Jerrico, Inc., 446 U.S. 238 (Due process requires an impartial and disinterested tribunal)
Liteky v. United States, 510 U.S. 540 (Courtroom administration, without extrajudicial bias, is not grounds for recusal)
Apprendi v. New Jersey, 530 U.S. 466 (Facts increasing penalty beyond statutory maximum must be found by a jury)
United States v. Hishaw, 235 F.3d 565 (Drug quantity must be submitted to jury and proved beyond a reasonable doubt under § 841(b)(1))
United States v. John, 849 F.3d 912 (Similar instruction on witness interviews upheld; did not preclude witness credibility attacks)