Seventh Circuit: USA v. Juan Adame


Crim, Interstate commerce, FRE


Sufficient evidence on merits.

Use of building for rental establishes interstate commerce requirement of the arson statute.

Historical cell site data admissible under Daubert, since it was appropriately qualified.  Ultimately harmless.

Agent testimony variations from deposition are not properly considered here, since the record was not amended to include the deposition version.

Fact that deft talked about fire on incidental audio associated with video allowed into jury room not overly prejudicial.

USA v.   Juan Adame