Criminal Law-Prison Assault-Sufficiency of Evidence-Sentencing Enhancement

Staff Report//May 20, 2026//

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Defendant appealed his conviction and sentence for assault causing serious injury during an altercation with a fellow prison inmate. Defendant challenged the sufficiency of the evidence and argued that the district court improperly limited his ability to cross-examine a witness. Defendant further contended that the government made improper, prejudicial comments during trial. Finally, defendant argued that the district court erroneously imposed a seven-level sentencing enhancement.

Where the jury chose to credit the victim’s version of events, there was sufficient evidence to prove that defendant committed assault, and the limitations on defendant’s cross-examination did not preclude him from questioning the victim’s credibility.

Judgment is affirmed.

U.S. v. Teztlaff (MLW No. 84773/Case No. 24-3389 – 15 pages) (U.S. Court of Appeals, 8th Circuit, Shepherd, J.) Appealed from U.S. District Court, Eastern District of Arkansas, Moody, J. (Sylvia Talley, AFPD, Little Rock, AR for appellant) (Chris Givens, AUSA, Little Rock, AR; Bart Dickinson, AUSA, Little Rock, AR; and John Dennis Webster, AUSA, Little Rock, AR for appellee)