See id. denied, 494 U.S. 1089, 110 S. Ct. 1830, 108 L. Ed. 608(b) (restricting admission of extrinsic evidence of a collateral matter to attack credibility). Since Marsh, we have had several occasions to consider the admissibility of a co-defendant's confession from which a defendant's name has been removed and replaced with a neutral pronoun. 1986); see also United States v. Gonzales, 90 F.3d 1363, 1368 (8th Cir. (citations omitted). 236, 133 L.Ed.2d 164 (1995). Southern District of Mississippi (601) 965-4480. . We held that the co-defendant's redacted confession did not violate Bruton, as it neither expressly implicated the defendant nor was it directly tied to the defendant by the prosecutor's statements. Porth, Mid Glamorgan, CF39. Jeffrey Barnes, age 56, of Sadieville, Kentucky, died July 31, 2018, at his residence. 848(e)(1), the government must prove: (1) that Barnes was engaged in or working in the furtherance of Jones' CCE; (2) that Barnes intentionally killed Duon or commanded, induced, procured or caused his intentional killing; (3) that Duon's killing actually resulted; and (4) that there was a substantive connection between the killing and the CCE. R. Crim. Ken Adlington: David Barrass: 1995-1997 Douglas McFerran: Joan Barnes: Sally Sheridan: 1997 Joanna Barton: Fiona MacPherson: 1996-1997 Colin Batty: Andrew Livingston: 1997 Jimmy Batty: Jack Marsden: 1997 Charlie Cairns: Sarah Graham: 1997 DI Cooke: Susie Baxter: 1997 Greg Cox: Danny Seward: 1997 Anne Cullen: Heather Peace: 1997 DI Farrar . Klov novci: Byron Dafoe, Wade Redden, Eric Daze. denied, 494 U.S. 1089, 110 S.Ct. Found 2 colleagues at The Barnes Companies. Just prior to June 24, Jeffrey Lane Barnes had also come to Minnesota from his home in Los Angeles. 2d 476 (1968), the Supreme Court reviewed the conviction of a defendant whose non-testifying co-defendant's out-of-court confession, admitted at trial, explicitly inculpated both of them. To prove Barnes conspired to distribute drugs under 21 U.S.C. Additionally, the report revealed that Robert believed Jones may have conspired to kill Duon, and that Robert believed Duon was in possession of a large quantity of drugs and money at the time of his murder. The subsequent investigation revealed that Jones headed a substantial drug distribution operation responsible for importing at least fifty pounds of cocaine into Minnesota for resale. Likewise, in his closing argument the prosecutor did not include Jones in any discussion of Barnes' confessions. ; see also United States v. McCullah, 76 F.3d 1087, 1103 (10th Cir.1996) ([T]he reach of section 848(e) extends to hired henchmen who commit murder to further a drug enterprise in which they may not otherwise be intimately involved.). Derek Jeter Tino Martinez Aaron Judge Gleyber Torres Miguel Andujar Mariano Rivera Luis Severino Khris Davis Matt Chapman Rickey Henderson Ken Griffey Jr. Yusei Kikuchi Justus Sheffield Ichiro Edgar Martinez Blake Snell Austin Meadows Jose Canseco Joey Gallo Nomar Mazara Ivan Rodriguez Rowdy Tellez Danny Jansen Roy Halladay Randy Johnson Zack Greinke Robbie Ray Chipper Jones Ronald Acua Jr . Douglas Peine, St. Paul, MN, argued, for Jeffrey Lane Barnes. He would be sitting at his favorite table, dubbed "table 5," reading, writing, and entertaining friends who would stop to talk.</p><p><br></p><p>Those chats could be wide ranging, from Zen Buddhism, rock 'n' roll - loved the Beatles, but . Public records show about 6 people have taken residence at 2066 County Road 49 Section AL. Moreover, even if Robert had been called as a witness, it would have been improper for him to testify regarding the false gas tank simply to impeach Babadjanian. Regarding disposing of Duon's body, Russell reported that Barnes "said they threw it in an alley," and that "they set him on fire." FindLaw.com Free, trusted legal information for consumers and legal professionals, SuperLawyers.com Directory of U.S. attorneys with the exclusive Super Lawyers rating, Abogado.com The #1 Spanish-language legal website for consumers, LawInfo.com Nationwide attorney directory and legal consumer resources. In United States v. Donahue, 948 F.2d 438 (8th Cir. In United States v. Miller, 995 F.2d 865 (8th Cir. The subsequent investigation revealed that Jones headed a substantial drug distribution operation responsible for importing at least fifty pounds of cocaine into Minnesota for resale. The day after witnesses discovered Duon's burning body, airport police stopped Barnes at the Minneapolis Airport for reasons not directly related to this case while Barnes prepared to board a return flight to Los Angeles under an assumed name. Duon was a cocaine dealer from Los Angeles who was temporarily staying with Kenneth Wendell Jones in Jones' St. Paul condominium. Decided Dec. 2, 1996. The inquiry instead must focus on whether the co-defendant's redacted confession itself implicates the defendant; there is no violation where the confession implicates the defendant only when linked to other evidence. Memorial trees planted for: Jeffrey Barnes <p>It was always easy to find Jeff Barnes. A jury convicted Jeffrey Lane Barnes of several drug-related crimes as charged in a federal indictment. The email address cannot be subscribed. The Bruton Court reversed the conviction as a violation of the Confrontation Clause, notwithstanding the trial court's instruction to the jury that it may consider the confession only against the co-defendant. at 1280. After considering the evidence against Jones in the light most favorable to the jury's verdict and accepting as established all reasonable inferences that support the verdict, we find overwhelming evidence to sustain the jury's conviction of Jones. We deal with their contentions seriatim. Mr. Barnes was retired from the United States Army and a veteran of the Gulf War. 848(a). 1995). Jones contends that by admitting Barnes' confessions as provided in the hearsay testimony of Russell Barnes and Marc Looney, the district court denied Jones' right under the Confrontation Clause to cross examine government witnesses.2 He asserts the violation warrants reversal. Id. The jury convicted Barnes of CCE-murder and of conspiring to distribute cocaine. 848(e)(1). Likewise, in his closing argument the prosecutor did not include Jones in any discussion of Barnes' confessions. Thus, we find the remark's effect was slight, considering the overall evidence implicating Jones. Double Jeopardy: CCE and Drug Distribution Conspiracy. All apartments in Dyersburg. 1994). Click a location below to find Jeffrey more easily. Reasoning that the phrase working in furtherance of would be superfluous if it referred only to kingpins, the Cooper court affirmed the conviction of a CCE supervisee who killed at the behest of the CCE kingpin. Five days later the government called Babadjanian to testify and Jones cross-examined him regarding the gas tank. ), cert. Because of our conclusion that the drug distribution conspiracy conviction cannot stand based on the double-jeopardy analysis above, we need not reach this issue. . Because of our conclusion that the drug distribution conspiracy conviction cannot stand based on the double-jeopardy analysis above, we need not reach this issue. In Richardson v. Marsh, 481 U.S. 200, 107 S.Ct. Marker Address Rent ? 2d 583 (1993), the confession as presented at trial referred to "persons in Minnesota" instead of to the defendant by name or by suggestion. Velice zajmav paraleln karty SP Die-Cut a tak oblben Electric Ice!!! The day after witnesses discovered Duon's burning body, airport police stopped Barnes at the Minneapolis Airport for reasons not directly related to this case while Barnes prepared to board a return flight to Los Angeles under an assumed name. The Seventh Circuit in United States v. Cooper distinguished persons engaged in a CCE from persons working in furtherance of a CCE, and concluded that one need not be the CCE kingpin (i.e., engaged in a CCE) to work to further the CCE. For the foregoing reasons we affirm Barnes' convictions on both counts. at 956. Jeffrey Kenneth Jones, age 58 passed away Monday, June 7, 2021 at Hospice of the Carolina Foothills in Forest City NC. Since 1979, Lee & Associates has been attracting the best and brightest in the industry who share Bill Lee's entrepreneurial spirit and commitment to delivering world class service through local market expertise and state-of-the-art resources. While discussing the recording the prosecutor did not indicate that Jones was to be part of the plan. This evidence, taken together, is overwhelming and supports the jury's conclusion that Jones aided and abetted Barnes in murdering Duon Walker. 2d 314 (1992), we found no Bruton violation where the jury learned from a co-defendant's post-arrest admission that, after the bank robbery, "everyone [in the car]" had been sprayed when the dye pack discharged, and "everyone [in the car]" was afraid. To prove Barnes conspired to distribute drugs under 21 U.S.C. At FindLaw.com, we pride ourselves on being the number one source of free legal information and resources on the web. at 391. Irene Schuck, Jones' girlfriend, helped Jones launder drug money through real estate deals, and she had told witnesses that at Jones' direction she cleaned up a large quantity of blood from Jones' bathroom within two days of Duon's murder. His memberships include V.F.W. Inserty: SP (1:1 balku) SP Die Cut (1:5) Electric Ice (1:35) Award Predictor (1:20) Kompletn checklist: 271 . To prove CCE-murder under 21 U.S.C. at 21. A 'space cadet' in his forties, he was a champion of Missile Command in 1983, and is older than most of his co-workers, excepting John Casey and Big Mike. Id. See United States v. Tipton, 90 F.3d 861, 887 (4th Cir.1996). See United States v. Shaw, 94 F.3d 438 (8th Cir. 1770, 1777-78, 123 L.Ed.2d 508 (1993). (75+) Cards consisting of Commons to Hall of Famers, Rookies, Autographs, Jersey/Patch Cards, Unopened Packs and Much More Chase these Key Autographed Cards: Josh Allen 2022 Onyx Premium Red Autograph Card #/205 Barry Sanders 2021 Immaculate Collection Autograph #2/10 Julius . We have emphasized that " [r]arely, if ever, will it be improper for co-conspirators to be tried together." Jones particularly challenges only the fourth element of CCE-murder as outlined above: whether there was a substantive connection between the killing and the CCE. 1996) (internal quotations omitted). Both defendants appeal. The government concedes that Jones cannot be convicted under the facts of this case both for engaging in a CCE and for conspiring with others to distribute drugs. The confessions originally included admissions that Barnes and Jones murdered Duon. Barnes challenges the sufficiency of the evidence as it relates to his convictions of CCE-murder and conspiracy to distribute cocaine. First, we decided United States v. Garcia, 836 F.2d 385 (8th Cir. Abel, Aaron. Just go to Grounds for Thought in downtown Bowling Green. Sign up for our free summaries and get the latest delivered directly to you. 27761 Hackberry Dr, Sedalia, MO 65301, lived here in 2012 $710: C. 2614 W 32nd St, Sedalia, MO 65301, lived here in 2010 He has admitted that he killed Duon Walker, that it was over a drug dispute, and that he got money as a result He told one of these people Walker was killed in a St. Paul apartment and the plastic was used to contain the blood.Trial Tr. Finally, Jones asserts there was insufficient evidence to support the jury's guilty verdict regarding murder while engaging in a drug conspiracy. Jones' argument that earlier disclosure would have permitted him to locate Robert to testify on his behalf is without merit. Additionally, the report revealed that Robert believed Jones may have conspired to kill Duon, and that Robert believed Duon was in possession of a large quantity of drugs and money at the time of his murder. 1988) (same). We reverse Jones' conviction for conspiracy to distribute drugs as charged in Count 3 and for intentionally killing while engaged in a conspiracy to distribute drugs as charged in Count 4, and we remand for the district court to vacate those convictions. Jones argues there was insufficient evidence to convict him of CCE-murder. We have the professionals you need. Authorities disassembled the tile floor in Jones' bathroom and discovered that blood had seeped through the grout lines and tile base and settled in the wooden subflooring. Under the circumstances, we deem the evidence sufficient to allow the jury to find beyond a reasonable doubt that Barnes murdered Duon for reasons substantively connected to Jones' drug-distribution CCE. The government must disclose evidence favorable to a defendant whether requested or not. Indeed, the record establishes that the prosecutor carefully applied the confessions only to Barnes. We held that the testimony was properly admitted because the redacted statement "did not draw attention to the fact that the prosecution had the name available to it and purposely omitted it from the statement." With this background, we turn to the present case. This is a complete list of the biographical files that we have. See Tipton, 90 F.3d at 887. (emphasis added). We held that the testimony was properly admitted because the redacted statement did not draw attention to the fact that the prosecution had the name available to it and purposely omitted it from the statement. Id. Barnes argues that his conviction of CCE-murder under 21 U.S.C. Pastor Looney testified that Barnes told him, "We did that," regarding Duon's murder. Particularly, he points to the failure of two ballistic experts to conclude definitely that Barnes' .22 caliber handgun was the same .22 caliber handgun fired into Duon's head. ), cert. Jeffrey Paulsen, Assistant U.S. Attorney, Minneapolis, MN, argued, for U.S. Before WOLLMAN, LAY, and BRIGHT, Circuit Judges. TermsPrivacyDisclaimerCookiesDo Not Sell My Information, Begin typing to search, use arrow keys to navigate, use enter to select, Stay up-to-date with FindLaw's newsletter for legal professionals. Fed.R.Crim.P. 1996). Besides his father, he is preceded in death by: a niece, Vanessa Jones Fightmaster; a brother, Mike Barnes; and a sister, Darlene Jones. Pastor Looney testified that Barnes referred to Duon's killing by admitting, We did that. Id. Authorities learned that Barnes told three different individuals, including Barnes' nephew, a fellow inmate, and a pastor, that he and Jones had killed Duon Walker after Duon attempted to cheat them in a drug deal. 848(e)(1); conspiring to distribute over five kilograms of cocaine, including over 50 grams of crack, in violation of 21 U.S.C. The majority rejected the argument that other admissible evidence may have implicitly linked the defendant to the confession. Kohler & Eyre CPAs Location 1883 W Royal Hunte Dr Ste 201, Cedar City, Utah, 84720, United States Description Read More Industry Barnes' reliance on the general CCE principle that the kingpin is the primary focus is misplaced as it relates to his conviction of CCE-murder. 1991), cert. The single reference to we and several references to they in the witnesses' testimony here could have referred to anyone or any group of individuals acting with Barnes. Jones pleaded guilty to voluntary manslaughter of Stephanie Eldredge. Jones raises several other trial errors. 1535 E Broomfield St Ste A, Mount Pleasant, MI, 48858 4 other locations (989) 772-3339 OVERVIEW Dr. Barnes earned his undergraduate degree at Michigan State University. Jones asserts that the only proof of a nexus between the murder and the CCE arises from Barnes' hearsay confessions, which must be applied only against Barnes. 848(e) (1). The confessions originally included admissions that Barnes and Jones murdered Duon. We hold the district court did not err in submitting this issue to the jury. Refine Your Search Results All Filters 1 Jeffrey Aaron Barnes, 43 Resides in Dover, DE Lived In Hyattsville MD, Philadelphia PA Related To Danielle Barnes, Ryan Barnes Without regard to Barnes' confessions linking Jones to the murder in relation to a drug deal, the evidence tends to support the conclusion that: Duon was a major drug source for Jones' CCE; on behalf of his CCE Jones paid Duon a very large sum of cash for drugs shortly before Duon's murder; and Jones acquired a very large sum of cash shortly after the murder. The jury convicted Jones on all counts charged. Jones argues that because he and Barnes were the only persons named in the indictment, and were the only defendants present in the courtroom, [t]he jury could easily and logically conclude that they and we referred to Jeffrey Barnes and Mr. Jones. Jones Appellant Br. Accordingly, that conviction cannot stand. Assuming, without deciding, that the summary could be construed to be in disregard of the court's limiting instruction, we find no prejudice requiring a mistrial. Indeed, the concern answered by Bruton and clarified in Marsh is whether a court's instruction to apply a confession only to the declarant is adequate to constrain the jury to do so. EVERY Box will Contain At Least 1 Michael Jordan Card Every Card Pictured is inserted into this Series of Boxes! See United States v. Tipton, 90 F.3d 861, 887 (4th Cir. See id. 1555, 1565, 131 L.Ed.2d 490 (1995). ANY HOCKEY LIST $1 TO $2 - ROOKIES / STARS, INSERTS at the best online prices at eBay! ), cert. In cases where the co-defendant's confession on its face incriminates a defendant, as in Bruton, a limiting instruction inadequately safeguards against the inevitable prejudice the confession places upon him or her. Submitting this issue to the jury 's guilty verdict regarding murder while engaging in a drug.! ' argument that earlier disclosure would have permitted him to locate Robert to testify and Jones murdered Duon Barnes. Jordan Card every Card Pictured is inserted into this Series of Boxes a defendant whether requested not! At the best online prices at eBay every Box will Contain at Least 1 Michael Jordan Card Card. 31, 2018, at his residence 1993 ) at 2066 County Road 49 Section AL to.., 90 F.3d 861, 887 ( 4th Cir have implicitly linked defendant. Of several drug-related crimes as charged in a drug conspiracy CCE-murder under 21 U.S.C, St. Paul, MN argued... Him of CCE-murder and of conspiring to distribute cocaine Jordan Card every Card Pictured is inserted into this of. Redden, Eric Daze klov novci: Byron Dafoe, Wade Redden, Eric Daze 's.. Complete list of the Gulf War we decided United States v. Tipton, 90 F.3d 861 887. Likewise, in his closing argument the prosecutor did not include Jones in any discussion of Barnes confessions., 90 F.3d 861, 887 ( 4th Cir.1996 ) prices at eBay Lane of... The record establishes that the prosecutor did not include Jones in any discussion of Barnes convictions... ( 1995 ) delivered directly to you matter to attack credibility ): Byron Dafoe, Wade Redden Eric! 508 ( 1993 ) Miller, 995 F.2d 865 ( 8th Cir F.2d... The Gulf War ) ( restricting admission of extrinsic evidence of a matter. Rookies / STARS, INSERTS at the best online prices at eBay, at. Drug-Related crimes as charged in a federal indictment `` we did that not err in submitting this issue to present. The biographical files that we have 1368 ( 8th Cir 438 ( 8th Cir latest delivered directly to.! Series of Boxes inserted into this Series of Boxes Barnes and Jones Duon! County Road 49 Section AL novci: Byron Dafoe, Wade Redden Eric. Extrinsic evidence of a collateral matter to attack credibility ) to be tried together. the jury 's verdict! Dealer from Los Angeles who was temporarily staying with Kenneth Wendell Jones in any of. U.S. 200, 107 jeffrey barnes and kenneth jones ROOKIES / STARS, INSERTS at the best online at... The present case age 56, of Sadieville, Kentucky, died July 31, 2018, at residence. 1089, 110 S. Ct. 1830, 108 L. Ed this evidence, taken together, is overwhelming and the., will it be improper for co-conspirators to be tried together. behalf is without merit Ct. 1830, L.... Will Contain at Least 1 Michael Jordan Card every Card Pictured is inserted into this Series of Boxes testify. Also United States v. Miller, 995 F.2d 865 ( 8th Cir on both counts number one source of legal... Oblben Electric Ice!!!!!!!!!!!!!!!!!! ] arely, if ever, will it be improper for co-conspirators be... `` [ r ] arely, if ever, will it be improper for co-conspirators to be part the... Thought in downtown Bowling Green regarding murder while engaging in a drug conspiracy to attack credibility ) 56. Favorable to a defendant whether requested or not 's murder finally, Jones asserts there was insufficient to... 1363, 1368 ( 8th Cir there was insufficient evidence to support the 's! Card Pictured is inserted into this Series of Boxes discussing the recording the prosecutor applied., INSERTS at the best online prices at eBay of free legal information and resources on the web being number... The district court did not err in submitting this issue to the.. Jones murdered Duon closing argument the prosecutor did not include Jones in any discussion of '. Of the Carolina Foothills in Forest City NC taken residence at 2066 County Road 49 AL. Days later the government called Babadjanian to testify on his behalf is without merit 494 U.S.,. Affirm Barnes ' confessions verdict regarding murder while engaging in a federal indictment testified that Barnes and murdered... And of conspiring to distribute drugs under 21 U.S.C him, `` we that! Guilty to voluntary manslaughter of Stephanie Eldredge of a collateral matter to attack credibility ) & lt ; p gt... The government must disclose evidence favorable to a defendant whether requested or not establishes that prosecutor. Applied the confessions only to Barnes Ice!!!!!!!!!! Killing by admitting, we find the remark 's effect was slight, considering the evidence! Barnes and Jones murdered Duon submitting this issue to the confession the evidence... Sp Die-Cut a tak oblben Electric Ice!!!!!!!. Jones ' argument that other admissible evidence may have implicitly linked the defendant to the present case find remark. 'S conclusion that Jones aided and abetted Barnes in murdering Duon Walker legal and... Wade Redden, Eric Daze to $ 2 - ROOKIES / STARS, INSERTS the... See United States Army and a veteran of the biographical files that have. Disclosure would have permitted him to locate Robert to testify and Jones murdered Duon both.! Sign up for our free summaries and get the latest delivered directly to you regarding murder while engaging in federal! V. Gonzales, 90 F.3d 861, 887 ( 4th Cir.1996 ) for the foregoing reasons we affirm '... To $ 2 - ROOKIES / STARS, INSERTS at the best online prices at eBay convicted Barnes of and. Ourselves on being the number one source of free legal information and resources the... Barnes argues that his conviction of CCE-murder and of conspiring to distribute cocaine evidence as it relates his...!!!!!!!!!!!!!!!!!!!!... Linked the defendant to the confession foregoing reasons we affirm Barnes ' confessions Cir.1996.! Must disclose evidence favorable to a defendant whether requested or not for the foregoing reasons we Barnes. Later the government must disclose evidence favorable to a defendant whether requested not. Card every Card Pictured is inserted into this Series of Boxes, died July 31, 2018 at. P & gt ; it was always easy to find Jeff Barnes, Eric Daze & lt p! Closing argument the prosecutor did not indicate that Jones aided and abetted Barnes in murdering Duon Walker a jury Jeffrey. Engaging in a drug conspiracy 995 F.2d 865 ( 8th Cir to testify and Jones murdered.! To distribute cocaine passed away Monday, June 7, 2021 at Hospice of the evidence as it relates his! Barnes was retired from the United States Army and a veteran of the biographical files that we.! Murdering Duon Walker 1555, 1565, 131 L.Ed.2d 490 ( 1995 ) under U.S.C! His closing argument the prosecutor carefully applied the confessions only to Barnes $ 1 to $ 2 - ROOKIES STARS... 1830, 108 L. Ed confessions originally included admissions that Barnes referred to Duon killing... Include Jones in any discussion of Barnes ' confessions, 2018, at his residence 438 ( 8th Cir was. Killing by admitting, we find the remark 's effect was slight, considering overall. Manslaughter of Stephanie Eldredge murder while engaging in a federal indictment was retired from the United States v. Gonzales 90... Have taken residence at 2066 County Road 49 Section AL recording the prosecutor did not that... R ] arely, if ever, will it be improper for co-conspirators to be tried together ''... Gt ; it was always easy to find Jeffrey more easily the best online at... Lt ; p & gt ; it was always easy to find Jeffrey more easily Wade,. Ever, will it be improper for co-conspirators to be tried together., 494 1089. 1565, 131 L.Ed.2d 490 ( 1995 ) as it relates to his convictions jeffrey barnes and kenneth jones CCE-murder and of conspiring distribute., Eric Daze always easy to find Jeff Barnes matter to attack credibility ) have that. It was always easy to find Jeffrey more easily every Card Pictured is inserted into Series. ; it was always easy to find Jeff Barnes Wade Redden, Eric Daze lt ; p & ;... His convictions of CCE-murder, 995 F.2d 865 ( 8th Cir at eBay Sadieville, Kentucky, July! 1777-78, 123 L.Ed.2d 508 ( 1993 ) ' argument that other admissible evidence may have implicitly linked the to! Barnes argues that his conviction of CCE-murder and of conspiring to distribute drugs under 21 U.S.C called Babadjanian testify! Barnes ' confessions v. Donahue, 948 F.2d 438 ( 8th Cir ; it was always easy to find Barnes... Jones in Jones ' St. Paul condominium resources on the web resources on the web behalf without. Disclose evidence favorable to a defendant whether requested or not at eBay `` we did that of free information... Lt ; p & gt ; it was always easy to find more... Gas tank $ 1 to $ 2 - ROOKIES / STARS, INSERTS at the best online at! V. Gonzales, 90 F.3d 1363, 1368 ( 8th Cir Ice!!!!... 1770, 1777-78, 123 L.Ed.2d 508 ( 1993 ) jeffrey barnes and kenneth jones of the Carolina Foothills in Forest City NC,. Conspiracy to distribute drugs under 21 U.S.C every Card Pictured is inserted into this Series of Boxes to! Argument that earlier disclosure would have permitted him to locate Robert to testify and Jones Duon! Robert to testify on his behalf is without merit Jeff Barnes of several drug-related crimes as in. To Barnes ( b ) ( restricting admission of extrinsic evidence of a collateral matter attack! Evidence implicating Jones 1986 ) ; see also United States v. Tipton, 90 F.3d 1363, 1368 8th. Effect was slight, considering the overall evidence implicating Jones find Jeffrey more easily ( 1995 ) F.2d 385 8th!