151254P.pdf   07/14/2016  United States  v.  Marcus Eason
   U.S. Court of Appeals Case No:  15-1254
   U.S. District Court for the Eastern District of Arkansas - Little Rock   
   [PUBLISHED] [Kelly, Author, with Murphy and Benton, Circuit Judges] 
   Criminal case - Criminal law and Sentencing. Based on defendant's 
   counsel's comments at the time counsel sought to use a dash cam video to 
   impeach the arresting officer, the video was not admissible as it was 
   extrinsic evidence and could not be used to impeach the witness; nor did 
   the court err in denying a subsequent attempt to play the video for the 
   jury as defendant had not disclosed the video prior to trial; in any 
   event, defendant has failed to explain how the witness could have been 
   further impeached by playing the video, and the court's ruling did not 
   have a sufficient effect on his rights or the verdict so as to require a 
   new trial; no error in refusing to admit defendant's photos of the scene 
   as defendant had violated Rule 16(b)(1)(A) by failing to produce them to 
   the government in pre-trial discovery; defendant has failed to show how 
   refusal to admit the photos affected his substantial rights as there were 
   no controverted issues the photos would have resolved; evidence was 
   sufficient to support defendant's conviction for being a felon in 
   possession of a firearm; defendant's prior conviction did not qualify as 
   predicate offenses for Armed Career Criminal Act sentencing under either 
   the residual clause or the force clause of the Act, and the matter is 
   remanded for resentencing.