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U.S. v. Figueroa-Lopez

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Bloomberg Law

Citation. 523 U.S. 1131

Brief Fact Summary. Following a jury trial, Raul Figueroa-Lopez (Defendant) was convicted of possession of cocaine with intent to distribute. At trial, the court allowed testimony of law enforcement officers into evidence, as lay witness testimony. Defendant appeals his conviction here.

Synopsis of Rule of Law. Testimony offered by law enforcement officers that profiles a criminal defendant as a drug trafficker is properly characterized as testimony based on the perceptions, education, training, and expertise of the witness, and therefore its admission or exclusion is governed by Federal Rule of Evidence 702, not lay opinion testimony under Federal Rule of Evidence 701.


Facts. Darryl Storm (Storm) was arrested for various drug offenses, and he agreed to cooperate with the authorities by supplying the names of narcotics traffickers. Storm gave the authorities Defendant’s first name only, stating that it was all he knew.
The narcotics agents with whom Storm was working instructed Storm to contact Defendant and to, “explore whether [Defendant] would sell him some narcotics.” Storm arranged, in a series of taped conversations with Defendant, to purchase 10 kilograms of cocaine from Defendant.
Storm eventually met Defendant in a parking lot to complete the deal and, when Defendant showed Storm 1 kilogram of the cocaine, officers arrested Defendant.
At Defendant’s trial, the prosecution called various law enforcement officials, who testified that Defendant’s behaviors, “conformed to the methods and techniques of experienced drug dealers.” All the testimony by the law enforcement officers was allowed into evidence as lay opinion testimony, over Defendant’s objection.

Issue. Did the lower court error by admitting the testimony of the law enforcement officers under Federal Rule of Evidence 701, without a proper foundation having been laid?

Content Type: Brief


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