Quick Summary
In United States v. Stever, Andrew Stever was convicted for manufacturing and conspiracy to manufacture marijuana. The conviction was based on evidence found on his mother’s property. Stever argued that Mexican drug trafficking organizations (DTOs) were responsible and sought discovery to support his defense, which the district court denied. The United States Court of Appeals for the Ninth Circuit reversed his conviction, citing a violation of his Sixth Amendment right to present a complete defense.
Facts of the Case
Andrew Stever lived with his mother on a 400-acre rural property. In July 2007, officers executed a search warrant on this property and discovered a marijuana growing operation in a remote corner bordering Forest Service land. Over 7000 marijuana plants were found, with most located on the Stever property and some on adjacent Forest Service land.
When officers arrived, two men described as Hispanic fled, leaving behind personal effects including an ID card for Alfredo Jesus Beltran-Pulido (Pulido), Stever’s business card, and Stever’s mother’s cell phone number. Phone records indicated frequent calls between Stever and numbers found at the scene.
Stever claimed he had hired Pulido and his associates to work on a generator and repair fences. Pulido stayed on the property for some time and socialized with Stever’s friends. Tire tracks from Stever’s truck matched those near the marijuana site.
In October 2007, Stever was indicted. He requested discovery of government reports on Mexican DTOs, suggesting they were responsible for the operation. His request was denied, as was his motion to bar the government from arguing his involvement with DTOs while also being barred from presenting evidence about DTOs himself.
At trial, unable to present an alternative explanation, Stever’s defense was limited to challenging the government’s case. The jury found him guilty on both counts.
Procedural History
- The United States Government charged Andrew Stever with manufacturing marijuana and conspiracy to manufacture marijuana in District Court.
- The District Court denied Stever’s motion to compel discovery regarding Mexican DTOs, ruling it irrelevant.
- Stever moved in limine to prevent the government from arguing his conspiracy with DTOs; the court also barred him from presenting any evidence about DTO involvement.
- The jury convicted Stever based on prosecution evidence.
- Stever appealed to the United States Court of Appeals for the Ninth Circuit, claiming violations of his Sixth Amendment rights due to denial of discovery and inability to present his defense theory.
I.R.A.C. Format
Issue
- Whether denying discovery about Mexican DTOs and preventing evidence presentation regarding their involvement violated Stever’s Sixth Amendment right to make a defense, impacting his conviction for manufacturing and conspiracy to manufacture marijuana.
Rule of Law
The Sixth Amendment guarantees defendants the right to present a complete defense.
Federal Rule of Evidence 401 states that evidence is relevant if it makes a fact more or less probable than it would be without the evidence, and that fact is of consequence in determining the action.
Reasoning and Analysis
Denying Stever’s motion for discovery concerning Mexican DTO operations hindered him from presenting an alternative explanation for the marijuana found on his property. This restriction compromised his Sixth Amendment right to a complete defense.
The requested materials were relevant under Federal Rule of Evidence 401 as they could indicate an alternative perpetrator for the marijuana operation, reducing the likelihood of Stever’s involvement. The proposed evidence included government reports and expert testimony about DTO activities that could have been assessed by the jury for their probative value concerning Stever’s alleged involvement.
This exclusion was not harmless beyond reasonable doubt since it directly impaired Stever’s ability to argue his defense theory effectively. Given much of the prosecution’s case was circumstantial, denying access to potentially exculpatory information undermined his right to a fair trial.
Conclusion
The United States Court of Appeals for the Ninth Circuit reversed Andrew Stever’s conviction. The court held that denying him access to discovery materials about Mexican DTOs and barring him from presenting such evidence violated his Sixth Amendment right to present a complete defense.
Concurring Opinions
Judge Marsha S. Berzon wrote a concurring opinion emphasizing that fundamental standards of relevance necessitated admitting testimony that could demonstrate someone other than Stever committed the crime.
Dissenting Opinions
None provided.
Key Takeaways
- Defendants have the constitutional right to present a complete defense under the Sixth Amendment.
- Evidence is relevant if it makes a fact more or less probable and is of consequence in determining the action, per Federal Rule of Evidence 401.
- Denying access to potentially exculpatory information that supports an alternative defense theory can undermine a fair trial.
- The Ninth Circuit held that preventing Stever from presenting evidence regarding Mexican DTO involvement violated his right to make a defense.
Relevant FAQs of this case
Was this case brief helpful?