DISCLAIMER: The following unofficial case summaries are prepared by the clerk's office
as a courtesy to the reader. They are not part of the opinion of the court.
192473P.pdf 10/06/2020 United States v. Lonnie Howard
U.S. Court of Appeals Case No: 19-2473
U.S. District Court for the District of North Dakota - Bismarck
[PUBLISHED] [Wollman, Author, with Gruender and Kobes, Circuit Judges]
Criminal case - Criminal law and sentencing. The evidence was sufficient
to support defendant's convictions for being a felon in possession of
ammunition and a firearm as the evidence showed defendant knowingly
possessed the weapon and ammunition; no error in admitting a pawn ticket
showing defendant had pawned a weapon four months earlier as it went to
show knowledge and intent to possess; further, the district court gave a
limiting instruction diminishing any prejudicial effect of the evidence;
no error in admitting a dashcam video showing defendant escaping from an
officer, as flight was evidence of consciousness of guilt; again, the
district court's careful instruction on the matter lessened the potential
for any prejudicial effect; defendant's Wisconsin conviction for armed
robbery and North Dakota conviction for conspiracy to deliver ecstasy were
qualifying offenses for Armed Career Criminal Act sentencing.