United States v. Lyle, No. 15-958 (2d Cir. 2017)Annotate this Case
The Second Circuit affirmed Defendants Lyle and Van Praagh's conviction and sentence for drug trafficking charges. The Second Circuit held that the district court did not err in denying Lyle's motion to suppress where he had no reasonable expectation of privacy in the rental car that he was driving without a license and without authority; Lyle's statement in his opening argument triggered the waiver of his proffer agreement, and the proffer statements rebutted his counsel's argument that he was a mere user of methamphetamine and not a dealer; the admission of Lyleʹs redacted proffer and post‐arrest statements in defendantsʹ joint trial was not plainly erroneous; the district court did not abuse its discretion in admitting the evidence seized during Lyleʹs New Jersey arrest; the district court did not plainly err in failing to sua sponte give a buyer‐seller instruction to the jury; and Van Praaghʹs below‐Guidelines sentence of 144 monthsʹ imprisonment was substantively reasonable.
The court issued a subsequent related opinion or order on April 1, 2019.