Law360 (June 2, 2026, 10:33 PM EDT) -- Lyrics and a music video were properly admitted as evidence against two rappers accused of being a part of a Kansas City, Missouri, drug trafficking ring, the Eighth Circuit has ruled, saying the relevance of the lyrics was "obvious" when affirming their convictions and prison sentences.

A three-judge panel rejected every argument four men charged with offenses connected to the drug operation put forward when challenging elements of their trials and convictions. The panel affirmed their prison sentences, which ranged from about 12.5 to 35 years, according to its Monday order.

Most notably, the panel upheld the admission of rap lyrics written and performed by Ladele D. Smith. He argued that admitting his lyrics was unfair because they were merely artistic expressions and not factual confessions. He claimed that allowing them at trial inflamed the jury, convincing it he was a violent drug dealer based on a fictional gang-like persona he adopted rather than the actual evidence.

But the panel disagreed, ruling the lyrics were properly admitted because they showed Smith understood code words for drugs, knew their prices and used firearms when trafficking them.

"Its relevance is obvious, tending to show that Smith and [a co-defendant] were part of a drug-trafficking conspiracy," it said.

Prosecutors charged Smith, David Duncan, Roy Franklin Jr. and Gary Toombs with participating in a drug-trafficking organization in Kansas City that allegedly lasted from 2011 to 2019. The government said all were part of a group called "246," which the prosecutors claimed was a music group that also sold marijuana, oxycodone, cocaine and heroin, according to the opinion. The government also accused Franklin and Smith of committing a drive-by shooting to protect Duncan, who was allegedly being threatened by two other men, according to the opinion.

The jury found all four guilty. Franklin was sentenced to 30 years in prison, Smith received 35 years, Duncan received 30 years, and Toombs received about 12.5 years, the opinion said.

The panel rejected arguments from Franklin that law enforcement lacked probable cause to wiretap him or secure a search warrant based on his Instagram messages from a private group chat.

The panel upheld the admission of Smith's rap lyrics along with his and Duncan's affiliation with the 246 group.

Smith was considered the lead or "star" of the group, and Duncan and others often appeared beside him in videos with guns and cash, the opinion said.

During the three-week trial, the government played about 12 minutes of clips from music videos and an interview with Duncan. In one clip, Smith rapped, "I sell dope, I don't sell Kush because that shit is slow. $15k profit every week, know I'm getting dough," the opinion said.

In one clip, Duncan wore a 246-branded baseball hat and talked about how the group formed, the opinion said. He said the group's music is "spittin' that real shit" and that "Everything [is] 100% authentic."

The court said this evidence was properly admitted and relevant.

"Smith's lyrics showed they knew the lingo, they knew about selling drugs, they knew about guns," the panel said. "The videos showed the defendants hanging out together with guns and cash. And the interview with Duncan explained the group's origins and suggested there was truth to the lyrics."

The government declined to comment Tuesday. Counsel for the defendants did not respond to requests for comment.

U.S. Circuit Court Judges L. Steven Grasz, David R. Stras and Jonathan A. Kobes sat on the panel for the Eighth Circuit.

Franklin is represented by John Johnston of Johnston Law Firm LLC.

Smith is represented by Angela C. Hasty of the Law Office of Angela C. Hasty LLC.

Duncan is represented by Joshua Adams of Law Offices of Joshua B. Adams PC.

Toombs is represented by Sean W. Pickett of Sean W. Pickett & Associates LLC.

The government is represented by Ashleigh Ragner, John Benton Hurst and Mary Kate Butterfield of the U.S. Attorney's Office for the Western District of Missouri.

The case is U.S. v. Franklin, case number 23-3118, in the U.S. Court of Appeals for the Eighth Circuit.

--Editing by Adam LoBelia.

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