United States v. Chavez, No. 17-8096 (10th Cir. 2020)Annotate this Case
Defendant-Appellant Randolfo Librado Chavez, Jr. was convicted by jury of two counts of distributing methamphetamine. His appeal of those convictions centered on the district court’s admission into evidence of three transcripts, which purportedly were of audio recordings of incriminating conversations that he had had in Spanish and in English. The district court did not admit into evidence the audio recordings themselves or play the recordings for the jury. In addition, the district court instructed the jury that they could not question the accuracy of the English-language translations in the transcripts. To the Tenth Circuit, Chavez challenged both the district court’s admission of the transcripts and the jury instructions relating to them, arguing the district court: (1) violated the best-evidence rule by admitting the transcripts into evidence without admitting the recordings themselves; and (2) committed plain error by instructing the jury to accept the accuracy of the translations in the transcripts. As to Chavez’s first contention, the Tenth Circuit concluded the district court’s admission of the transcripts, without also admitting the recordings they purported to transcribe, violated the best-evidence rule and constituted reversible error. Accordingly, it reversed and remanded the case to the district court with instructions to vacate Chavez’s convictions and grant him a new trial. In light of that disposition, the Court did not reach the merits of Chavez's jury-instruction challenge.