United States v. Mercado-Gracia, No. 19-2153 (10th Cir. 2021)Annotate this Case
Defendant Aaron Mercado-Gracia challenged his three convictions for drug trafficking, conspiring to traffic drugs, and using a firearm in relation to a drug-trafficking offense. In upholding his convictions, the Tenth Circuit found the district court did not err in denying Mercado-Gracia’s motion to suppress evidence discovered as the result of a traffic stop. The traffic stop evolved into a consensual encounter during which the police officer developed reasonable suspicion to believe Mercado-Gracia was involved in drug trafficking. That reasonable suspicion justified a brief investigative detention, during which the officer deployed his drug-sniffing dog, which alerted, leading to the discovery of a gun and two kilograms of heroin in the car Mercado-Gracia was driving. Furthermore, the district court did not abuse its discretion in denying Mercado-Gracia’s request to play during voir dire a video to educate prospective jurors on implicit bias. Thus, finding no reversible error, the Tenth Circuit affirmed Mercado-Gracia's convictions.