United States v. Rodriguez-Flores

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Defendants Jose Remberto Guzman-Dominguez and Miguel Angel Rodriguez-Flores were arrested at a state port of entry after an inspector found cocaine and heroin in their tractor-trailer. The truck contained a large quantity of legitimate cargo, but four boxes containing the drugs, weighing more than 115 pounds, were concealed behind that cargo. After a joint trial in federal district court, defendants were convicted on all three counts of the indictment against them: (1) conspiracy to distribute at least five kilograms of cocaine and at least one kilogram of heroin; (2) possession with intent to distribute at least five kilograms of cocaine; and (3) possession with intent to distribute at least one kilogram of heroin. The primary issue before the district court was whether Defendants knew of the contraband in the truck. Both had denied knowledge in statements to law-enforcement officers after their arrests. Guzman-Dominguez repeated the denial of knowledge in his trial testimony. Rodriguez-Flores did not testify. On appeal Rodriguez-Flores challenged the sufficiency of the evidence that he knew of the contraband in the truck, and both Defendants challenged the unobjected-to admission of a statement by an expert witness that he did not believe persons transporting drugs who denied knowledge of the drugs. The Tenth Circuit determined the evidence was more than sufficient for a reasonable juror to infer beyond a reasonable doubt that Rodriguez-Flores was involved in the drug offenses, and on plain-error review of the admission of the expert testimony, the Court held Defendants did not show the prejudice necessary to require reversal. View "United States v. Rodriguez-Flores" on Justia Law