DC Circuit: USA v. Juan Vega


Crim

Stream of commerce suffices for circumstantial evidence that deft intended cocaine to reach US.

Sufficient instruction on mens rea.

Urging in closing that jury serve as community conscience and use of first person singular was harmless error, given strength of case.

 False testimony not later corrected by govt was not dispositive.

Not issuing missing evidence instruction on lack of govt records on out of court photo lineups was harmless error.

No Brady violation on late-disclosed photo with attribution problems.

No error in refusal to admit notes frm quesitoning as prior inconsistent statement.

Error in manager/supervisor sentencing bump, as no showing that employees knew they were doing something illegal.

No error in admission of mistaken identification, given curative instruction.

Deft claim that Title III has no extraterritorial application, even if true, would not preclude extraterritorial wiretapping.

No error in denial of cross on why cooperating witnesses were wearing electronic monitoring devices.

Drug making video not overly prejudicial.



USA v. Juan Vega