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2025 Supreme(US)(ca8) 57

COURT OF APPEALS FOR THE EIGHTH CIRCUIT
United States – Appellant
Versus
Najawaun Quinn – Respondent



No. 23-2842 ___________________________

United States of America

lllllllllllllllllllllPlaintiff - Appellee

v. Najawaun Marcus Quinn, also known as Fat Boy or Fat Boi

lllllllllllllllllllllDefendant - Appellant ___________________________

No. 23-2885 ___________________________

United States of America

lllllllllllllllllllllPlaintiff - Appellee

v.

Dimetri Alexander Smith, also known as Metri

lllllllllllllllllllllDefendant - Appellant ____________

Appeals from United States District Court for the Southern District of Iowa - Eastern ____________ Submitted: September 26, 2024 Filed: March 19, 2025 ____________ Before COLLOTON, Chief Judge, LOKEN and SHEPHERD, Circuit Judges. LOKEN, Circuit Judge.

A January 2023 Third Superseding Indictment charged Najawaun Quinn, Dimetri Smith, and three others with 18 counts of racketeering and firearm offenses involving shootings and other racketeering activity while the defendants were associated with the Savage Life Boys Gang (“SLB Gang”) in Davenport, Iowa. The other three defendants pleaded guilty. After a lengthy trial, a jury found Quinn guilty of assault with a dangerous weapon in aid of racketeering in violation of 18 U.S.C. § 1959(a)(3) (Count 1); use of a firearm in relation to a crime of violence in violation of 18 U.S.C. § 924(c)(1)(A) (Count 2); and being a felon in possession of a firearm or ammunition in violation of 18 U.S.C. §§ 922(g)(1) and 924(a)(2) (Count 3). It found Smith guilty of two counts of assault with a dangerous weapon in aid of racketeering in violation of 18 U.S.C. §§ 2 and 1959(a)(3) (Counts 8 and 17) and two counts of use of a firearm in relation to a crime of violence in violation of 18 U.S.C. §§ 2 and 924(c)(1)(A) (Counts 10 and 18). The district court denied their renewed motions for judgment of acquittal. See Fed. R. Crim. P. 29.

In these consolidated appeals, Quinn and Smith appeal their convictions and sentences, raising numerous issues. For the following reasons, we conclude the district court1 committed no reversible error and therefore affirm.

1 The Honorable Rebecca Goodgame Ebinger, United States District Judge for the Southern District of Iowa.

-2- I. Background

A. The Racketeering Statute. The primary issues on appeal concern the convictions of Quinn and Smith for counts charging Violent Crimes in Aid of Racketeering Activity in violation of 18 U.S.C. § 1959. The statute provides as relevant here:

(a) Whoever . . . for the purpose of gaining entrance to or maintaining or increasing position in an enterprise engaged in racketeering activity . . . assaults with a dangerous weapon . . . against any individual in violation of the laws of any State . . . or attempts or conspires so to do, shall be punished--

(3) for assault with a dangerous weapon or assault resulting in serious bodily injury, by imprisonment for not more than twenty years . . . .

(b) As used in this section-- (1) “racketeering activity” has the meaning set forth in section 1961 of this title; and (2) “enterprise” includes any partnership, corporation, association, or other legal entity, and any union or group of individuals associated in fact although not a legal entity, which is engaged in, or the activities of which affect, interstate or foreign commerce.2

2 Section 1959, first enacted in 1984, is part of Chapter 95 of T

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