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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.