Court: Court of Appeals for the Eighth Circuit; October 3, 2001; Federal Appellate Court
David M. Reynolds was found guilty by a jury of theft of property moving in interstate commerce, interstate transportation of stolen property, and conspiracy to commit these offenses, violating various sections of the U.S. Code. The case stemmed from an incident on February 7, 1998, when Reynolds, employed by Mo-Kan Container Services, picked up a container containing Nike shoes from a railroad yard, which was later discovered to have been broken into with 125 cases missing. On February 11, 1998, during a traffic stop involving Reynolds' brother, Tom, officers found 315 pairs of stolen shoes in a U-Haul trailer rented by David.
During the trial, defense counsel sought to cross-examine Officer Shiers about syringes found in Tom Reynolds' vehicle, arguing it was relevant to demonstrate Tom's drug habit and motive for the theft. The district court denied this request, citing relevance concerns. Tom Reynolds, after being granted immunity, testified against David, admitting to stealing the shoes with him. He described their actions, including replacing the original container seal and selling the shoes in Arkansas. The defense was allowed to question Tom about prior convictions, including possession of methamphetamine, and other related activities, despite no convictions for some of the actions mentioned. The court ultimately affirmed David Reynolds' conviction.
Defendant sought to recall Officer Shiers to testify about syringes found in Tom Reynolds' vehicle to challenge Reynolds' credibility. The district court denied this request, citing that the testimony would be cumulative. On July 11, 2000, the jury convicted the defendant on all counts, leading to a sentence of twenty-four months imprisonment and three years of supervised release. The appeal centers on whether the district court erred in excluding evidence of the syringes. The defendant argued that this evidence was admissible under Rule 404(b) to demonstrate Reynolds' motive linked to his drug habit; however, the court found this irrelevant since Reynolds admitted to stealing the shoes in question. The court noted that the cross-examination of Officer Shiers was limited, as he could not confirm ownership or intent regarding the syringes. The evidence was deemed only marginally relevant and properly excluded. The court also emphasized that ample impeaching evidence against Reynolds was already presented, including his admission of a methamphetamine conviction and inquiries into his fraudulent activities. Consequently, the district court's decision to exclude the syringe evidence as cumulative was upheld, and the appellate court affirmed the district court’s ruling.
