United States v. Reynolds, No. 22-1431 (6th Cir. 2023)
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Reynolds was convicted of selling a fentanyl-heroin mixture that killed two young men, 21 U.S.C. 841(a)(1). Investigators connected Reynolds to these fatal drugs in part through cellphone records, including records showing the general locations of several phones; text messages, including messages between a detective pretending to be one of the victims and Reynolds; and a controlled buy arranged by that detective.
The Sixth Circuit affirmed the conviction and 328-month sentence, rejecting arguments that the government introduced insufficient evidence to convict; that a government expert identified the phones’ general locations using a software program that failed the “Daubert” reliability standards; that the district court violated the Constitution by excluding text messages that allegedly supported his innocence; and that the prosecutor improperly “vouched” for a key government witness during closing arguments.
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