United States v. Garcia, No. 13-4136 (4th Cir. 2014)
Annotate this CaseDefendant appealed his convictions on five counts of narcotics trafficking. The court held that the district court abused its discretion in its evidentiary rulings as viewed in their totality. The court held that safeguards adopted by the district court to avoid the substantial risk of prejudice inhering in the jury's receipt of the decoding expert's testimony was inadequate. Neither the district court's cautionary instructions to the jury nor its sporadic sustaining of some of counsel's objections adequately mitigated the risk of substantial prejudice. Further, the errors were not harmless. Although the court discerned no reversible error in the district court's denial of the motion for judgment of acquittal, the court held that the errors in the decoding expert's testimony so infected the entire trial that the court vacated and remanded for further proceedings.
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