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United States v. Jacobs

3rd Circuit

December 16, 2021

The Third Circuit affirmed the defendant’s convictions but vacated the sentence for distributing and conspiring to distribute fentanyl and heroin that caused someone’s overdose death. The defendant made claims about the sufficiency of the evidence, the jury instructions, the jury panel, and the sentence. First, in challenges to the sufficiency of the evidence, the Court noted that it reviews the verdict for “bare rationality,” asking only whether any reasonable juror could find the defendant guilty beyond a reasonable doubt. The Court held that though the Government did not prove the crimes with 100% certainty, it was not required to do so. A rational juror could have decided the defendant was guilty beyond a reasonable doubt after drawing inferences from the evidence and testimony presented at trial. Second, the District Court did not commit plain error in its jury instruction concerning causation and the crime of drug delivery resulting in death. Next, the Court ruled that the “District Court properly engaged in a thorough dialogue with counsel and scrutinized the evidence before determining that the Government’s race-neutral reasons in striking a juror were not pretextual”. Lastly, the Court remanded for clarification of the sentence because the District Court imposed a “general sentence” without explaining which parts of the sentence were attributable to the three counts of conviction.

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