Eighth Circuit: US v. Kwame Askia

Federal embezzlement statute is not a continuing offense; once the threshold has been reached, the offense is complete.  For purpose of the stature of limitations, however, so long as the limit is reached within the relevant timeframe, the fact that the offense began earlier doe not bar the indictment.

No plain error in introduction of evidence of theft outside the statute of limitation's timeframe; no sixth amendment claim arising from pro se / standby.

Hearsay claim arising out of pretrial detention hearing moot. No 6A claim.

Sufficient evidence.

http://media.ca8.uscourts.gov/opndir/18/06/171515P.pdf