United States v. Trent, No. 16-3960 (7th Cir. 2017)Annotate this Case
Trent was charged with distributing heroin that killed Corzette. At trial, Trent objected to the testimony of government witnesses Hull and Land, who had also been charged with distribution of heroin resulting in Corzette’s death. The two pled guilty. Trent sought to impeach them based on their plea agreements with questions about the 20-year mandatory minimum associated with the heroin-distribution-resulting-in-death charges. Trent faced the same 20-year mandatory minimum if convicted. The district court noted that, if the jury became aware of the exact length of Hull’s and Land’s mandatory minimum, it would also know the minimum penalty that Trent faced, which could improperly sway its decision. The court prevented Trent from asking about the mandatory minimum’s exact length but permitted him to describe the mandatory minimum as “substantial.” Trent also objected to the testimony of Illinois State Police Sergeant Rieck, who had investigated Trent while undercover, communicating with Trent in person and by telephone. At trial, Rieck identified Trent’s voice in phone calls. Trent objected to this identification, claiming that the government had not laid the necessary foundation. The Seventh Circuit affirmed Trent’s conviction and 300-month sentence, rejecting arguments that the limitation on questioning Hull and Land violated his Sixth Amendment right to confrontation and challenging the admission of Rieck’s testimony.