United States v. Raymond Tetzlaff

── United States v. Raymond Tetzlaff ── Court: Court of Appeals for the Eighth Circuit Date: May 13, 2026 Category: General United States Court of Appeals For the Eighth Circuit ___________________________ No. 24-3389 ___________________________ United States of America Plaintiff - Appellee v. Raymond Tetzlaff Defendant - Appellant ____________ Appeal from United States District Court for the Eastern District of Arkansas - Delta ____________ Submitted: November 20, 2025 Filed: May 13, 2026 ____________ Before COLLOTON, Chief Judge, SHEPHERD and ERICKSON, Circuit Judges. ____________ SHEPHERD, Circuit Judge. Raymond Teztlaff was convicted of one count of assault causing serious bodily injury stemming from an altercation with another prison inmate, after which the district court 1 sentenced him to 120 months’ imprisonment followed by 3 years 1 The Honorable James M. Moody, Jr., United States District Judge for the Eastern District of Arkansas. of supervised release, with the term of imprisonment running consecutively to an undischarged term of imprisonment for another federal offense. Tetzlaff appeals both his conviction and sentence, asserting that the evidence was insufficient to support his conviction; that the district court erroneously limited Tetzlaff’s ability to cross examine a witness; that the Government made improper and prejudicial comments during trial, which deprived him of a fair trial; and that the district court improperly applied a seven-level sentencing enhancement. Having jurisdiction under 28 U.S.C. § 1291, we affirm in full. I. “We recite the facts in the light most favorable to the jury’s verdict.” United States v. Galloway, 917 F.3d 631, 632 (8th Cir. 2019) (citation omitted). Raymond Tetzlaff was indicted on one count of manslaughter, in violation of 18 U.S.C. § 1112, and one count of assault causing serious bodily injury, in violation of 18 U.S.C. § 113(a)(6), related to an incident that occurred while he was a federal inmate housed at the Forrest City Federal Correctional Complex. Another inmate, Mack Bowens, testified that he observed an argument between Tetzlaff and a third inmate, Ben McGraw, with Tetzlaff accusing McGraw of stealing a contraband cell phone that belonged to Tetzlaff. Bowens saw Tetzlaff sucker punch McGraw in the head, and McGraw fall to the floor, where he lay, bleeding from the head and unmoving for five to six minutes. Later, Tetzlaff’s cellmate, Ronald Haas, saw McGraw sitting in a chair with a towel over his head and staring at the floor. Haas also observed a deep gash on the back of McGraw’s head. Further, Haas testified that Tetzlaff told Haas that he had “dropped” McGraw, and that McGraw was unconscious for over eleven minutes. Haas also overheard Tetzlaff telling another inmate about the incident, and, when referring to his punch of McGraw, stating that “it works every time.” McGraw’s cellmate, Michael Rimlawi, who had been a physician prior to his incarceration, testified that, shortly after the altercation, he checked on McGraw and noticed immediately that “something wasn’t right.” Rimlawi explained that he observed a three- to four-inch-long laceration on the back of McGraw’s head that -2- was half an inch wide. Rimlawi testified that, based on the severity of the injury, he told McGraw to seek medical care and that he heard Tetzlaff tell McGraw to say he fell in the shower if asked about the cause of his injuries. Rimlawi also testified that he asked Tetzlaff what was