United States v. Watson

The Eighth Circuit affirmed defendant's conviction and sentence for distributing five or more grams of actual methamphetamine. The court rejected defendant's claims of evidentiary errors; the government did not impermissibly vary from the facts charged in the indictment; and the jury's verdict was supported by sufficient evidence and the district court properly denied defendant's motion for judgment of acquittal. The court also held that any procedural error at sentencing did not affect the calculation of defendant's criminal history score. Furthermore, defendant's sentence was substantively reasonable where the district court explained its sentencing decision, recounting defendant's long history of violent conduct and considered the need to protect the community. Therefore, the district court properly weighed the 18 U.S.C. 3553(a) factors and did not abuse its discretion in sentencing defendant to 180 months in prison. View "United States v. Watson" on Justia Law