United States v. Michael Anderson

MEMORANDUM

Michael Anderson appeals the district court’s denial of his Federal Rule of Criminal Procedure 29(a) motion, asserting that the government presented insufficient evidence for a rational fact-finder to infer Anderson knew that he possessed a machine gun in violation of 18 U.S.C. § 922 (o). We have jurisdiction pursuant to 28 U.S.C. § 1291 , and we affirm.

When considering a claim of insufficiency of the evidence, the court views the evidence in the light most favorable to the government and determines if any rational trier of fact could have found the defendant guilty of the essential elements of the crime beyond a reasonable doubt. Jackson v. Virginia, 443 U.S. 307, 319 , 99 S.Ct. 2781 , 61 L.Ed.2d 560 (1979). Knowledge can be inferred from circumstantial evidence. Staples v. United States, 511 U.S. 600 , 616 n. 11, 114 S.Ct. 1793 , 128 L.Ed.2d 608 (1994). Here, Anderson kept a collection of thirty-one high-quality firearms, numerous accessories, and nearly 35,000 rounds of ammunition. He saved multiple receipts for his purchases. He possessed two nearly identical semi-automatic military rifles but for the modifications that converted one of the weapons into a machine…