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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.