United States v. Gutierrez-Ramirez, No. 18-2270 (8th Cir. 2019)
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The Eighth Circuit affirmed defendant's conviction for knowingly possessing with the intent to distribute five kilograms or more of a mixture or substance containing a detectable amount of cocaine. The court held that there was no error in admitting bad act evidence under Federal Rule of Evidence 404(b), because the evidence of the prior law enforcement in Arizona was relevant to the material issue of knowledge and intent and was similar in kind to the offense in this case. Furthermore, the potential prejudice outweighed its probative value, and the district court gave an appropriate limiting instruction.
The court also held that the district court did not plainly err in permitting a police officer to testify on drug dealing practices. The government offered the testimony to rebut the "unknown courier defense," and the officer testified that it was highly unlikely a drug dealer/trafficker would entrust someone ignorant of their responsibility for a very valuable shipment.
Court Description: Per Curiam - Before Smith, Chief Judge, and Arnold and Kelly, Circuit Judges] Criminal case - Criminal law. The district court did not err in admitting bad act evidence under Rule 404(b) as the evidence of a prior law enforcement encounter in Arizona was relevant to prove knowledge and intent and was similar in kind to the offense charged; the potential prejudice from admitting the evidence did not outweigh its probative value and the court gave an appropriate limiting instruction to the jury; the district court did not plainly err in permitting a police officer to testify on drug dealing practices, including that it was unlikely that a drug trafficker would entrust more than $200,000 worth of cocaine to a person unaware of what was happening after defendant presented a defense that she was completely ignorant that she was transporting five kilos of the drug.
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