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United States v. Alexander
Citation: 20 F. App'x 12Docket: Nos. 00-1143(L), 00-1177(C)
Court: Court of Appeals for the Second Circuit; September 10, 2001; Federal Appellate Court
The judgment of the District Court is affirmed regarding the convictions of William Snaggs and Bertram Steven Alexander for conspiracy to commit robbery, multiple counts of robbery, and using firearms in connection with those robberies. Both appellants raised a total of six claims. Snaggs argues: 1. The District Court abused its discretion by excluding Detective Basil Nonis's testimony, which was deemed of little relevance and likely to confuse the jury. 2. The District Court improperly instructed the jury on his alibi. 3. His sentence improperly included uncharged conduct related to a robbery during the conspiracy. The court found that the exclusion of Detective Nonis’s testimony was within the District Court's discretion. Regarding his sentencing, the court upheld that the analysis was consistent with precedent allowing for the separate grouping of relevant conduct offenses. Alexander claims: 1. Insufficient evidence regarding the robbery's effect on interstate commerce, which was found meritless since the burden is minimal. 2. The District Court erred in sentencing him as a career offender. 3. The imposition of enhancements for uncharged robberies was incorrect. The court rejected Alexander's claims, affirming that the jurisdictional requirement was met and that the District Court acted correctly in its sentencing decisions. Overall, the court found all claims from both appellants to be without merit and affirmed the original judgment.