First Circuit: US v. Agramonte-Quezada

 Absent a showing of bad faith or prejudice, discovery delay in producing dog training records and logs did not require the trial judge to grant a continuance, as there were other discovery materials that might have opened the door to a challenging of the canine evidence.

Evidence of a prior canine indication was more probative than prejudicial, since the switching of vehicles in the interval and the deft's awareness of the narcotics traffic spoke to a continuing plan or scheme and rebutted the claim that he had been an unwitting courier.

Law enforcement testimony as to the usual trafficking operation wasn't impermissible overview testimony, as it came at the end of the trial, the witness was insulated from the particular case, and didn't reference any particulars.  Lay testimony of this nature gleaned from on-the-job experience is helpful to the finder of fact, and therefore permissible.

Court did not abuse its discretion in proceeding to sentencing rather than considering competency; the determination had been made earlier,and nothing in the colloquy prior to sentencing indicated sufficient incapacity. 

US v. Agramonte-Quezada