United States v. Gondres-Medrano, No. 20-4105 (4th Cir. 2021)Annotate this Case
The Fourth Circuit affirmed defendant's conviction and sentence for possession with intent to distribute a mixture containing fentanyl and heroin. The court concluded that police had probable cause to search the shoebox for drugs under the automobile exception where the officers used a reliable informant who had provided accurate information in the past and where officers corroborated significant parts of the informant's information. The court also concluded that the district court did not abuse its discretion by admitting a video that showed defendant opening a heroin package under Federal Rule of Evidence 403 where it was highly probative to the government's case and to undermining defendant's defense. Finally, the court concluded that there was no error in the district court's application of a two-level sentencing enhancement for obstruction of justice under USSG 3C1.1 for perjury during sentencing.