US v. Adams, 08-4143

Crack cocaine related conviction

US v. Adams, 08-4143, concerned a defendant's challenge to his conviction and sentence for possession with intent to distribute and conspiracy to distribute crack cocaine.

In affirming the conviction, the court held that the evidence of prior police encounters were directly related to the charged conspiracy, should not have been excluded under Rule 404(b) as prior bad act evidence, and was not unduly prejudicial under Rule 403.  The court also held that any confrontation clause errors in the admissions of a confidential informant's statements were harmless. Lastly, the prosecutor's remarks did not deprive defendant of a fair trial.  In affirming the sentence, the court held that, because the change in 21 U.S.C. section 841 of the Fair Sentencing Act of 2010 is not retroactive, it does not affect defendant's sentence.

Related Link:

• Read the Seventh Circuit's Full Decision in US v. Adams, 08-4143