United States v. William Parrott

Summary

The Eighth Circuit affirmed William Parrott's conviction for conspiring to distribute 500 grams or more of methamphetamine and his 300-month sentence, rejecting the thirteen trial and sentencing errors he alleged. The panel held that the district court properly admitted a police detective's expert drug testimony without a Daubert hearing, evidence from searches of alleged co-conspirators' property, co-conspirator hearsay, firearms-transaction testimony, Cellebrite text-message exhibits, and GPS tracker records, none of which was unauthenticated, unfairly prejudicial, or more than harmless error. It further held the evidence sufficient, found no cumulative error and no clear error in the drug-quantity finding or the firearm and premises-maintenance enhancements, and concluded the sentence was substantively reasonable where the court expressly considered the mitigating factors and varied downward from the guideline range.