DISCLAIMER: Any unofficial case summaries below are prepared by the clerk's office
as a courtesy to the reader. They are not part of the opinion of the court.
193159P.pdf 09/17/2020 United States v. Demetrius Jefferson
U.S. Court of Appeals Case No: 19-3159
U.S. District Court for the Southern District of Iowa - Des Moines
[PUBLISHED] [Loken, Author, with Grasz, Circuit Judge, and Clark, District
Judge]
Criminal case - Criminal law and sentencing. Evidence was sufficient to
support defendant's convictions for possession of marijuana with intent to
distribute, possession of a firearm in furtherance of a drug trafficking
crime and being a felon in possession of a firearm; the district court did
not abuse its discretion in denying defendant's motion for new trial as:
(1) the government's closing argument stayed within the permissible
parameters of Rule 404(b); (2) the court did not err in admitting forensic
testimony by the government's experts as their testimony on the absence of
DNA and fingerprints on the firearms and ammunition was relevant and
helpful to the jury; and (3) the court did not err in admitting a photo of
defendant in handcuffs taken during the warrant search as the photo
established defendant's presence, and the court gave a cautionary
instruction that the fact that defendant was in handcuffs was not
indicative of anything and was done for safety purposes; the court did not
err err in sentencing defendant as a career offender under Chapter 4 of
the Guidelines as his drug offenses qualified as controlled substance
offenses; no error in imposing an enhancement under Guidelines Sec.
2D1.1(b)(12) for maintaining a drug premises; no error in imposing an
enhancement under Guidelines Sec. 3B1.1 for leadership role in the
offense.