## Facts

- A fire occurred on April 9, 1998, at the St. Clair One‑Stop Convenience Store, owned by the defendant’s parents and operated by the defendant and his wife.
- Shortly before the fire, the defendant and an employee closed the store; the employee testified the defendant briefly reentered alone for about a minute, then set the alarm and left.
- The security system recorded the alarm set at 11:02 p.m. and motion detected inside at 11:06 p.m.; firefighters later extinguished the blaze.
- Responding officers observed no signs of forced entry; the defendant later entered the store with an officer and retrieved cash, lottery tickets, and a gun.
- A county fire investigator inspected the scene and concluded the fire originated at floor level in the furnace storage room and was deliberately set by a person, after ruling out multiple accidental causes.
- The insurer’s fire cause-and-origin expert similarly concluded the fire was deliberately set at floor level using ordinary combustibles in the furnace room.
- The defense suggested alternative explanations (including electrical arcing and rapid spread due to stored styrofoam) and presented an expert who could not determine the point of origin with reasonable certainty and could not conclude arson.
- The store faced serious financial problems, including tax delinquencies and an imminent threat of business-license revocation.
- At trial, the defendant sought to testify that the county investigator had previously said the fire started in the ceiling, contradicting his later floor-origin conclusion; the court excluded this testimony.

## Issues

1. Whether the district court abused its discretion under Federal Rule of Evidence 613(b) by excluding the defendant’s extrinsic impeachment testimony about the investigator’s alleged prior inconsistent statement when the investigator was not confronted with it on cross-examination.
2. Whether the evidence was sufficient for a rational jury to find beyond a reasonable doubt that the defendant committed arson affecting interstate commerce under 18 U.S.C. § 844(i).

## Decision

- The court affirmed the conviction and sentence.
- The court held the district court did not abuse its discretion in excluding the defendant’s impeachment testimony under Rule 613(b) because the witness was not first given an opportunity to explain or deny the statement and the “interests of justice” exception did not compel admission.
- The court held the evidence was sufficient, viewed in the light most favorable to the verdict, to support the jury’s finding of intentional arson.

## Legal Principles

- Under Federal Rule of Evidence 613(b), extrinsic evidence of a prior inconsistent statement is generally admissible only after the witness has an opportunity to explain or deny it and the opposing party has an opportunity to examine the witness about it; trial courts have broad discretion in applying the rule and sequencing impeachment.
- A conviction is supported by sufficient evidence if, viewing the record in the light most favorable to the government and drawing reasonable inferences in favor of the verdict, a rational jury could find each element beyond a reasonable doubt; circumstantial evidence can be enough, and appellate courts do not reweigh credibility.
- In arson prosecutions, opportunity, motive, timing evidence, and expert testimony excluding accidental causes may collectively permit a reasonable inference of intentional burning.

## Conclusion

The Eighth Circuit upheld the arson conviction, concluding the trial court acted within its discretion by excluding extrinsic impeachment not presented in compliance with Rule 613(b) and that the government’s circumstantial proof—timing and opportunity, financial motive, and expert opinions supporting an intentionally set fire—was adequate for a rational jury to convict.


United States v. Schnapp, 322 F.3d 564 (8th Cir. 2003)