182981P.pdf   03/05/2020  United States  v.  Darren Warren
   U.S. Court of Appeals Case No:  18-2981
                          and No:  18-3019
   U.S. District Court for the Southern District of Iowa - Davenport   
   [PUBLISHED] [Wollman, Author, with Colloton and Benton, Circuit Judges] 
   Criminal case - Criminal law and sentencing. Defendants' convictions on 
   drug and firearms charges were supported by the evidence; no error in 
   denying defendant Pugh's motion for a jury instruction on spoliation of 
   evidence; assuming such an instruction is available in a criminal case, it 
   is only appropriate upon a showing of bad faith, and there was no such 
   showing here; no error in admitting under Rule 404(b) a certified copy of 
   Pugh's information and guilty plea on an Illinois attempted robbery as the 
   evidence, which showed Pugh possessed a weapon during that offense, was 
   relevant to show knowledge and intent; Rehaif argument rejected as there 
   was sufficient evidence for a jury to find Pugh knew of his prohibited 
   status and because he could not show a reasonable probability of a 
   different outcome absent the claimed instructional error; no error in 
   calculating Pugh's offense level as his Illinois conviction for attempted 
   robbery is a crime of violence for purposes of Guidelines Sec. 
   2K2.1(a)(4)(a); a defendant's general denial of guilt places his state of 
   mind at issue, and it was not error to admit evidence of defendant 
   Warren's prior firearm and drug convictions; Warren's Rehaif arguments 
   rejected for the reasons discussed on Pugh's Rehaif claim.