United States v. Jeremy Burton

Summary

The court affirmed Burton’s conviction and sentence, holding that the district court properly excluded pharmacological expert testimony because it was offered primarily to support an impermissible voluntary-intoxication theory and did not adequately establish relevance to Burton’s alternative-planting defense. The court also held that the below-Guidelines sentence was substantively reasonable because the district court properly considered the relevant sentencing factors and did not improperly penalize Burton for testifying. Judge Kelly dissented, concluding that the expert testimony was relevant to whether Burton knowingly possessed the firearm and would have reversed for a new trial.