203103P.pdf   07/27/2021  United States  v.  Kenneth Still
   U.S. Court of Appeals Case No:  20-3103
   U.S. District Court for the Southern District of Iowa - Western   
   [PUBLISHED] [Wollman, Author, with Colloton and Kobes, Circuit Judges] 
   Criminal case - Criminal law and sentencing. In this prosecution for being 
   a felon in possession of a firearm, defendant moved to present a 
   justification defense; the district court did not err in denying the 
   request as a defendant seeking a justification instruction must produce 
   evidence that he took reasonable steps to dispossess himself of the weapon 
   once the threat entitling him to possess it abated; here, defendant had 
   reasonable, legal alternatives to his continued possession of the firearm 
   after a shooting and his continued possession of the gun and his failure 
   to dispose of it properly were fatal to his justification defense; in 
   calculating defendant's offense level, the district court did not err in 
   applying a voluntary manslaughter cross-reference; even if the court erred 
   in applying the cross-reference, the error was harmless as the court 
   stated it would have varied upward to the same sentence if it had not 
   applied the cross-reference; the district court did not clearly err on 
   this record in applying an obstruction-of-justice enhancement based on its 
   determination that defendant had attempted to destroy or conceal evidence; 
   the sentence imposed was not substantively unreasonable.