First Circuit: US v. Ocean

Sufficient evidence for conspiracy despite conflict with others and dual role as consumer and salesman for the drug operation -- the common purpose was the increased sale of narcotics.

Absent evidence that the government was attempting to elicit statements from the deft, contents of phone call during pretrial detention to friend who might have been cooperating with the investigation admissible.

Explicit waiver of drug quantity calculation in sentencing memo forecloses challenge on appeal.

District court was within discretion to accept deft's possibly exaggerated calculation of drug quantity.

Reference on cross to lab reports did not inappropriately bronze lay testimony as to drug identification or present confrontation clause argument as to the content of the reports.

http://media.ca1.uscourts.gov/pdf.opinions/16-2468P-01A.pdf