United States v. Paul Parrow

── United States v. Paul Parrow ── Court: Court of Appeals for the Eighth Circuit Date: April 15, 2026 Category: General United States Court of Appeals For the Eighth Circuit ___________________________ No. 25-1215 ___________________________ United States of America Plaintiff - Appellee v. Paul Antonio Deon Parrow, also known as Paul Antonio Deon Parrow, Jr. Defendant - Appellant ____________ Appeal from United States District Court for the Southern District of Iowa - Eastern ____________ Submitted: December 18, 2025 Filed: April 15, 2026 ____________ Before GRUENDER, KELLY, and ERICKSON, Circuit Judges. ____________ ERICKSON, Circuit Judge. A jury found Paul Parrow guilty of conspiracy to distribute a controlled substance and possession with intent to distribute a controlled substance, in violation of 21 U.S.C. §§ 846 and 841(a)(1), (b)(1)(A) and (b)(1)(B). The district court imposed concurrent terms of imprisonment of 300 months. Parrow appeals, challenging an evidentiary ruling and the denial of his motion for a mistrial. For the reasons that follow, we vacate Parrow’s conviction for possession with intent to distribute and remand for a new trial. We affirm the district court’s judgment in all other respects. I. BACKGROUND In March 2022, law enforcement performed a traffic stop involving N.G. She had methamphetamine on her person and told law enforcement that she received the drugs from Parrow, who is also known as “Tone.” N.G. agreed to act as a confidential informant. While being recorded by law enforcement, N.G. made four controlled buys from Parrow. During the first controlled buy, she purchased crack cocaine and marijuana. N.G. purchased methamphetamine from Parrow in the other three controlled buys. Law enforcement conducted surveillance of Parrow and identified a house on Esplanade Avenue that he was leasing. On November 3, 2022, police executed a search warrant for the Esplanade Avenue house and recovered methamphetamine and fentanyl from a safe. Police also recovered drug packaging material, digital scales, a kilo press, and items containing drug residue. Following Parrow’s indictment, the district court entered a discovery order that required the government to provide the defense with copies of all relevant law enforcement reports, witness statements, and memoranda of witness interviews prepared by law enforcement. Among other things, the government disclosed notes of an interview with D.B. and notes of an interview with someone identified only as a “concerned citizen.” Unbeknownst to the defense, the concerned citizen was D.B. In July 2024, the case went to trial. The jury heard from several witnesses including Parrow’s co-conspirators and customers. One of Parrow’s dealers testified that he initially received one to two ounces of methamphetamine but eventually built up to receiving between three quarters of a pound and one pound of -2- methamphetamine during his resupply meetings with Parrow. He then sold the methamphetamine to a co-conspirator in a quarter pound and half pound quantities and also enlisted his girlfriend to sell methamphetamine to her customers. The evidence showed he paid Parrow in cash and through Cash App. Documentary evidence of the Cash App transactions were submitted as an exhibit to the jury. He also testified that he typically saw Parrow with at least one pound of methamphetamine when he received his distribution and, on one occasion, saw Parrow with two pounds of methamphetamine. Two more Parrow dealers also te