United States v. Valbrun, No. 16-1806 (1st Cir. 2017)Annotate this Case
The First Circuit affirmed Defendant’s conviction, rendered after a jury trial, for knowingly possessing with intent to distribute heroin and crack cocaine and of aiding and abetting the same. Defendant appealed, arguing that the district court erred in allowing parts of a witness’s testimony about intercepted cellphone calls and erred in instructing the jury on willful blindness. In affirming, the First Circuit held (1) the district court did not abuse its discretion in allowing lay opinion testimony about the meaning and purport of intercepted conversations in which he had participated; and (2) the willful blindness instruction was justified in this case.