United States v. Darryl Anthony McNeal

CourtCourt of Appeals for the Sixth Circuit
DecidedApril 4, 2025
Docket24-5722
StatusUnpublished

This text of United States v. Darryl Anthony McNeal (United States v. Darryl Anthony McNeal) is published on Counsel Stack Legal Research, covering Court of Appeals for the Sixth Circuit primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
United States v. Darryl Anthony McNeal, (6th Cir. 2025).

Opinion

NOT RECOMMENDED FOR PUBLICATION File Name: 25a0186n.06

Case No. 24-5722

UNITED STATES COURT OF APPEALS FOR THE SIXTH CIRCUIT

FILED Apr 04, 2025 ) UNITED STATES OF AMERICA, ) KELLY L. STEPHENS, Clerk Plaintiff-Appellee, ) ) ON APPEAL FROM THE UNITED v. ) ) STATES DISTRICT COURT FOR ) THE WESTERN DISTRICT OF DARRYL ANTHONY MCNEAL, ) TENNESSEE Defendant-Appellant. ) ) OPINION

BEFORE: THAPAR, BUSH, and LARSEN, Circuit Judges.

THAPAR, Circuit Judge. Darryl McNeal appeals his conviction for possession with intent

to distribute methamphetamine. He argues that there wasn’t enough evidence for a jury to find

him guilty. Because there was, we affirm.

I.

This case began when Tennessee investigated Darryl McNeal for suspected distribution of

methamphetamine. As part of this investigation, agents asked a confidential source to buy

methamphetamine from McNeal two times: on March 10 and March 13, 2020. Both times,

McNeal sold the drugs to the source.

A grand jury indicted McNeal with two counts of knowingly and intentionally distributing

and possessing with the intent to distribute more than 50 grams of methamphetamine. See 21

U.S.C. § 841(a)(1). During a three-day trial, the jury heard from three officers who participated No. 24-5722, United Sates v. McNeal

in the undercover buys, the confidential source who bought the drugs, and two chemistry experts.

The jury found McNeal guilty. The district court then sentenced him to 300 months in prison, with

five years of supervised release. McNeal appealed, arguing that there wasn’t enough evidence for

a jury to have convicted him.

II.

A.

To assess McNeal’s challenge, we view the evidence in the light most favorable to the

government and ask whether any rational trier of fact could have convicted him. Jackson v.

Virginia, 443 U.S. 307, 319 (1979). Our review is constrained: we don’t weigh evidence, make

credibility determinations, or substitute our judgment for the jury’s verdict. United States v.

Crossley, 224 F.3d 847, 855–56 (6th Cir. 2000).

B.

There was sufficient evidence that McNeal knowingly distributed methamphetamine. The

government had to establish that the defendant knowingly distributed a controlled substance.

21 U.S.C. § 841(a)(1); United States v. Forrest, 17 F.3d 916, 919 (6th Cir. 1994). It did just that

for both dates in question.

Start with March 10. The jury heard sufficient evidence that McNeal knowingly distributed

methamphetamine on this date. The jury learned that the government ensured the source didn’t

have any drugs by searching her before the buy. The officers also searched the vehicle the source

would ride in to make the controlled buy. There was nothing in that car. Further, an officer drove

the informant to the purchase site and watched her during the purchase. A video showed the source

speaking to McNeal via phone while she was riding to the location. The source left the police-

driven vehicle to make the buy. And she then made a controlled purchase from a man she

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identified as McNeal. Then she returned to the officers’ car, which drove away. After getting to

a safe location, the officers searched the source and recovered the purchased substance, which later

tests revealed to be methamphetamine.

At trial, officers and the source testified to this sequence of events. And the government

presented video evidence, too. All told, there was significant evidence that McNeal distributed

methamphetamine on March 10.

Next, consider the significant evidence that the jury heard about the March 13 controlled

buy. Again, the key testimony came from both government agents and the same confidential

source. The jury heard that police again searched the confidential source before the buy. And they

learned that the source called McNeal, who drove his own vehicle to the scene and parked nearby.

Then the jury found out that the source got out of the agent’s car and went straight to McNeal’s

car. The source said she bought five ounces of methamphetamine from McNeal. The police then

picked up the source, took her back to a meeting place, and collected the substance, which tested

positive for methamphetamine.

As with the March 10 purchase, the agents and the confidential source provided extensive

testimony about the March 13 buy. There was also video evidence of the purchase. Thus, there

was sufficient evidence that McNeal knowingly distributed methamphetamine on March 13.

C.

McNeal makes several counterarguments, but none are convincing.

1.

First, McNeal attacks the government’s use of two videos at trial. The videos showed the

police interacting with the source, the source speaking with McNeal on the phone and meeting

McNeal in his car. McNeal says that the videos show “nothing more than [the source] using her

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cellphone to record basically her lap, her hand, the roof of the undercover vehicle, and the side of

Agent Allen’s head.” Appellant Br. at 14. McNeal’s argument seems to be that the videos don’t

show that McNeal committed the crime.

But video evidence isn’t necessary to prove that McNeal sold the drugs. Circumstantial

evidence alone can sustain a conviction. United States v. Henley, 360 F.3d 509, 513 (6th Cir.

2004). Indeed, even if the jury didn’t have the benefit of the videotape, there would still be

significant evidence to support its decision to convict: officer testimony connecting McNeal to

the distribution of drugs. What matters is whether a rational trier of fact could have found

sufficient evidence to convict. That standard is met here, even without the videos.

2.

McNeal next argues that the controlled buys didn’t follow the police procedures that help

prevent confidential sources from fabricating the amount of drugs they buy and the amount of

money they receive from law enforcement. McNeal contests three things: (1) the searches of the

confidential source; (2) the counting of funds used in the transactions; and (3) the officers’

supposed inability to see the source physically obtain the drugs because she was inside a car.

Start with the searches. The thrust of this claim is that the jury heard inconsistent testimony

about how the officers searched the source. For example, McNeal argues that at one point, an

agent testified he had searched the confidential source and the vehicle. Yet the source later said

that a different, female officer had searched her on both days.

This dispute doesn’t undercut the weight of the evidence. To be sure, it’s a discrepancy.

But it’s the kind of inconsistency that speaks to credibility—something an attorney can exploit on

cross-examination, as McNeal’s attorney did at trial. Those credibility determinations go to the

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quality of the evidence, not its sufficiency. See United States v. Ledbetter, 929 F.3d 338

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Related

Jackson v. Virginia
443 U.S. 307 (Supreme Court, 1979)
Daubert v. Merrell Dow Pharmaceuticals, Inc.
509 U.S. 579 (Supreme Court, 1993)
United States v. Timothy Wade Forrest
17 F.3d 916 (Sixth Circuit, 1994)
United States v. David E. Henley, Jr.
360 F.3d 509 (Sixth Circuit, 2004)
United States v. Robert Ledbetter
929 F.3d 338 (Sixth Circuit, 2019)

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