United States v. Crippen
United States Court of Appeals for the Eighth Circuit
627 F.3d 1056 (2010)

- Written by Kelli Lanski, JD
Facts
William Crippen (defendant) was convicted of conspiracy to manufacture methamphetamine and conspiracy to tamper with a witness. On the conspiracy charge, the government presented evidence that Crippen obtained pseudoephedrine pills and other products required to make methamphetamine, that he cooked the drugs along with a coconspirator, and that police arrested Crippen during a traffic stop during which they found drug residue, among other evidence. As to the witness-tampering charge, the government presented evidence that while Crippen was in jail on the drug charges, he had several phone calls with his mother. During the calls, Crippen and his mother allegedly discussed how they could prevent Crippen’s coconspirator from testifying against Crippen, including by threatening violence against the coconspirator and his family. Crippen appealed, arguing that the evidence was insufficient to support a finding of the overt act required to prove either conspiracy.
Rule of Law
Issue
Holding and Reasoning (Shepherd, J.)
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