Second Circuit: United States v. Alston

Off-duty police officer who carries a weapon at the direction of the police force can still be charged for possessing a weapon in furtherance of the illegal acts, as weapons can be possessed for multiple reasons.

No error in denial of new trial based on the fact that one of the witnesses mis-stated their employment status.

Post-verdict jailhouse infractions of witness do not give rise to a Brady claim.

No error in denial of minor participant sentencing reduction, as the deft's interference with law enforcement allowed criminal conspiracy to proceed; similar logic for obstruction and breach of trust sentencing enhancements.