United States v. Medina-Copete, No. 13-2026 (10th Cir. 2014)
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A series of appeals came before the Tenth Circuit brought by Maria Vianey Medina-Copete and Rafael Goxcon-Chagal following their convictions on drug trafficking charges. The issue these cases presented to the Court were one of first impression. At trial, the district court allowed a purported expert on certain religious iconography to testify that veneration of a figure known as "Santa Muerte" was so connected with drug trafficking as to constitute evidence that the occupants of the vehicle were aware of the
presence of drugs in a secret compartment. In addition to qualifying a law enforcement official as an expert on Santa Muerte, the court allowed the witness to wander far
afield and render theological opinions about the "legitima[cy]" of Santa Muerte in relation to other venerated figures. Upon review of these cases, the Tenth Circuit concluded that the law enforcement officer was improperly vetted under Fed. R. Evid. 702, "Daubert v. Merrell Dow Pharmaceuticals," (509 U.S. 579 (1993)), and "Kumho Tire Co. v. Carmichael," (526 U.S. 137 (1999)), and that the testimony proffered was both impermissible and prejudicial. The Court reversed the convictions and ordered a new trial.
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