United States v. EFF

BENAVIDES, Circuit Judge:

Appellant Ryan James Eff (“Eff’) appeals his conviction on three counts of arson in violation of 18 U.S.C. § 844(f)(1) and (2), asserting that the district court erred by excluding the testimony of his two expert witnesses supporting his insanity defense. We affirm the conviction because when considering the appropriate reach of the expert testimony and other evidence in the light most favorable to Eff, the evidence was insufficient to warrant a jury instruction on insanity.

I

Eff worked as a firefighter for the United States Forest Service (“USFS”). Beginning in May…