United States v. Williams
Opinion
OPINION
Curtis Hutaft Williams appeals his convictions for making a false statement to a federally licensed firearms dealer in the acquisition of a firearm, in violation 18 U.S.C.A. § 922(a)(6) (West 2000), and possession of a firearm by a convicted felon, in violation of 18 U.S .C.A. § 922(g)(1) (West 2000). He contends that the evidence was insufficient to convict him. We affirm.
In assessing the sufficiency of the evidence, the relevant question is not whether the court is convinced of guilt beyond a reasonable doubt, but rather whether the evidence, when viewed in the light most favorable to the government, was sufficient for a rational trier of fact to have found the essential elements of the crime beyond a reasonable doubt. Glasser v. United States, 315 U.S. 60, 80, 62 S.Ct. 457, 86 L.Ed. 680 (1942); United States v. Stewart, 256 F.3d 231, 250 (4th Cir. 2001) (citing United States v. Burgos, 94 F.3d 849, 863 (4th Cir. 1996) (en banc)). If substantial evidence exists to support a verdict, the verdict must be sustained. Glasser, 315 U.S. at 80, 62 S.Ct. 457.
Our review of the trial testimony leads us to conclude that the evidence was sufficient to convict Williams of knowingly making a false statement in violation of § 922(a)(6). United States v. Dillon, 150 F.3d 754, 759 (7th Cir. 1998) (discussing elements of offense); United States v. Hester, 880 F.2d 799, 802-3 & n. 4 (4th Cir. 1989) (holding that “knowingly” may be shown by actual knowledge or by “deliberate disregard for [the statement’s] truth or falsity with a conscious purpose to avoid learning the truth”). In addition, because Williams stipulated that he had been convicted of a felony and that Ids civil rights had not been restored, we find that the evidence was sufficient to support Williams’ conviction for being a felon in possession of a firearm. United States v. Gallimore, 247 F.3d 134, 136 (4th Cir. 2001) (discussing elements of § 922(g)(1) offense); United States v. Harrison, 204 F.3d 236, 240 (D.C.Cir.) (“It is well settled that a defendant, by entering into a stipulation, waives his right to assert the government’s duty to present evidence to the jury on the stipulated element.”), cert. denied, 531 U.S. 911, 121 S.Ct. 262, 148 L.Ed.2d 190 (2000); United States v. Reedy, 990 F.2d 167, 169 (4th Cir. 1993) (finding that defendant may not argue on appeal that evidence is insufficient to support element to which he stipulated).
Accordingly, we affirm Williams’ convictions. We dispense with oral argument *153 because the facts and legal contentions are adequately presented in the materials before the court and argument would not aid the decisional process.
AFFIRMED.
Reference
- Full Case Name
- UNITED STATES of America, Plaintiff-Appellee, v. Curtis Hutaft WILLIAMS, Defendant-Appellant
- Status
- Unpublished