United States v. Valdez, No. 11-3086 (D.C. Cir. 2013)
Annotate this CaseDefendant appealed his sentence and conviction for drug conspiracy. The court concluded that the district court did not abuse its discretion in admitting Federal Rule of Evidence 404(b) evidence of prior drug activity and in denying defendant's motion requesting that the drug conspiracy charge and the witness tampering charge be severed for purposes of trial where, in both instances, the district court gave reasoned explanations for its decisions and the jury was given limited instructions. The court also concluded that the prosecutor's improper remarks did not substantially prejudice defendant. In regards to defendant's sentence, the court concluded that defendant was not entitled to safety-valve relief where he had not fulfilled all the requirements of 18 U.S.C. 3553(f) and, consequently, his counsel was not ineffective for not arguing the issue with more vigor. Finally, the district court correctly determined that it did not have the discretion to award a United States v. Smith departure of any length beneath the statutory minimum. Accordingly, the court affirmed the judgment.
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