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232211P.pdf 03/01/2024 United States v. Ledra Craig
U.S. Court of Appeals Case No: 23-2211
U.S. District Court for the Eastern District of Missouri - St. Louis
[PUBLISHED] [Shepherd, Author, with Smith, Chief Judge, and Gruender,
Circuit Judge]
Criminal case - Criminal law. The district court properly admitted text
messages between defendant and an unidentified coconspirator in which
defendant sought to procure drugs, where overwhelming evidence of the
conspiracy existed and the texts were made in furtherance of the
conspiracy; coconspirator statements are nontestimonial, and their
admission did not violate defendant's Confrontation Clause rights; the
district court's decision not to allow defendant to ask a DA agent whether
he violated agency policy by making a cellphone recording of a statement
did not prejudice defendant as he was allowed to ask the witness numerous
questions about the circumstances of the recording; the district court did
not err in admitting 404(b) evidence of defendant's 2015 conviction for
distribution of a controlled substance as the evidence was relevant to his
intent, and any possible prejudice was lessened by the district court's
cautionary instruction.