United States v. Hilliard

490 F.3d 635 (2007)

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United States v. Hilliard

United States Court of Appeals for the Eighth Circuit
490 F.3d 635 (2007)

RW

Facts

The federal government (plaintiff) prosecuted Tyrone Hilliard (defendant) for multiple drug and firearms offenses, including possession of firearms in furtherance of drug trafficking in violation of 18 U.S.C. § 924(c). The trial evidence established that police officers searched a house and found Hilliard in illegal possession of cocaine and a handgun, which as a convicted felon, it was illegal for Hilliard to possess. Six months later, officers saw Hilliard engage in an apparent drug transaction at the same house. The officers searched the house once more, and found substantial cash and other valuables, cocaine stashed in the kitchen, drug-packing paraphernalia, and a handgun beneath a pillow in Hilliard's bedroom down the hall from the kitchen. Hilliard admitted keeping the cocaine to help him pay bills, and admitted possessing a gun illegally. Hilliard said that he kept the gun for personal protection. A police detective gave expert testimony that drug dealers often keep guns for personal protection, and that a gun found in proximity to valuables and drugs was often an indicator of illegal drug trafficking. The jury convicted Hilliard. On appeal to the Eighth Circuit Court of Appeals, Hilliard argued that the evidence was insufficient to find him guilty of the § 924(c) offense.

Rule of Law

Issue

Holding and Reasoning (Riley, J.)

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