Eighth Circuit: US v. Kevin Morrisey

Plain error not to instruct jury that Possession, as a lesser included offense of Receipt, could not be proved with respect to the same items.

Improper venue claim waived by counsel at trial.

Shift in the theory of the offense that would have encompassed crimes outside of the court's jurisdiction did not constitute a constructive amendment of the indictment, as venue is not an essential element of the offense. 

Plain error to admit spreadsheet with list of images with outside expert hearsay commmentary, but no prejudice.

No prejudice from statement in closing that implied that files could be received by when internally transferred.

http://media.ca8.uscourts.gov/opndir/18/06/172157P.pdf