United States v. Smith, No. 16-4746 (4th Cir. 2019)
Annotate this CaseThe Fourth Circuit affirmed defendants' conviction of crimes related to their participation in illegal activities in a street and prison gang known as the Black Guerrilla Family. The court rejected defendants' contention that the district court improperly handled the fears some jurors expressed after learning of the gang's predilection for violence and retaliation, and held that the trial judge made reasoned judgments in walking the line between detecting bias and creating bias. The court also held that the district court had broad discretion in evaluating the significance of potential juror bias and the trial judge acted well within its discretion in denying a mistrial. The court rejected defendants' claim that the district court should have excluded an FBI agent's expert testimony decoding intercepted calls, and held that there were no Confrontation Clause problems with the agent's testimony. Nevertheless, any error would have been harmless.
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