United States v. Garrett, No. 13-1182 (7th Cir. 2014)
Annotate this CaseGarrett was convicted of possessing with intent to distribute 50 or more grams of crack cocaine and sentenced to 190 months in prison. The Seventh Circuit affirmed his conviction, but vacated the sentence. The district court properly denied his motion to suppress post-arrest statements and information recovered from a search of his cell phone; intercepted phone calls, eyewitness testimony, and recovery of money and drugs establish that the officers had probable cause for arrest. The district court reasonably found that Garrett consented to a search of his cell phone. The court rejected an argument that it was error to allow the investigating agent to testify as an expert in the drug trade, noting that the judge did not permit reference to the officer as an expert before the jury. In instructing the jury not to consider potential punishment, the court did not misstate the law or mislead the jury. Use of an outdated verdict form did not prejudice Garrett; he received the benefit of the Fair Sentencing Act’s reduced penalties at sentencing. In calculating the appropriate Guidelines range for Garrett’s drug offense, however, the court did not clearly state the drug quantity that it found attributable to Garrett or adequately indicate the evidence it found reliable in determining his relevant conduct.
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