U.S. v. Bell

Record contained sufficient evidence to support jury’s guilty verdict on 1^st degree murder charge arising out of incident recorded by prison camera, where defendant-prisoner left his cell while hiding something in his pants and walked to victim’s cell, where victim was observed stabbed in throat shortly after defendant left victim’s cell. While defendant argued that record failed to contain sufficient evidence of premeditation, jury could properly find that defendant left his cell with plan in place to murder victim, and that because there was no real sign of struggle in victim’s cell, defendant executed his plan to kill victim in efficient manner pursuant to said plan. Record also supported co-defendant’s conviction on aiding and abetting defendant’s murder of victim, where recording indicated that co-defendant acted in coordination both before and after defendant commission of murder in that: (1) co-defendant took post outside cell while defendant was inside victim’s cell; and (2) co-defendant disposed of defendant’s weapon and clothing shortly after defendant returned to his cell. Dist. Ct. also did not abuse her discretion in ordering shackling of co-defendant at trial, where co-defendant had criminal history that included violent crimes, as well as prison disciplinary history that included possessing weapons and engaging in violent acts. Fact that co-defendant had no history of disrupting judicial proceedings did not require different result.