United States v. Perez-Couvertier, No. 16-2186 (1st Cir. 2020)
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The First Circuit affirmed Defendant's conviction of possessing with intent to distribute controlled substances in a protected area and conspiring to distribute controlled substances in a protected area, holding that the district court did not plainly err with respect to any of Defendant's challenges.
Specifically, the First Circuit held (1) the district court did not commit plain error in admitting evidence of the conspiracy's activities occurring after he withdrew from the conspiracy or, alternatively, in not instructing the jury to ignore such evidence; (2) the district court did not plainly err in admitting evidence of a drug trafficking organization's violent acts; and (3) the delay between Defendant's indictment and arrest did not violate his Sixth Amendment right to a speedy trial.
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