Cramer
United States v. Cramer
Opinion
Lead Opinion
MEMORANDUM **
Douglas Lee Cramer appeals his conviction for being a felon in possession of a firearm in violation of 18 U.S.C. § 922 (g)(1). Appellant argues that the district court erred on several evidentiary and trial-management rulings. We affirm.
1. Appellant argues that the trial court’s termination of defense counsel’s opening statement was an abuse of discretion and a violation of his due process right to a trial free of partiality and unfairness. We review the district court’s decision on issues of trial management for abuse of discretion. United States v. Goode, 814 F.2d 1353, 1354 (9th Cir.1987).
Although we find that the trial judge improperly limited counsel’s opening statement, the error was harmless beyond a reasonable doubt. See United States v. Taren-Palma, 997 F.2d 525, 532 (9th Cir. 1993) (per curiam) (applying harmless error analysis to the district court’s management of an opening statement), overruled on other grounds by United States v. Shabani, 513 U.S. 10 , 115 S.Ct. 382 , 130 L.Ed.2d 225 (1994). Prior to the termination of her opening statement, counsel was able to present her theory of defense and provide some information about the organization and…