United States v. Abdirahman Hassan, 20-30013

Abdirahman Ahmed Hassan owned East Africa Grocery (EAG), an authorized SNAP retailer since July 2010.
Indicted and convicted by a jury for a scheme to fraudulently obtain SNAP benefits: 18 counts of wire fraud, 1 count of illegally obtaining SNAP benefits, and 1 count of stealing government property; sentenced to eight months.
Government presented an expert who calculated that EAG’s average monthly SNAP transaction count and dollar volume were many times higher than those of other small grocery stores in the state.
Hassan does not dispute the calculations but contends the expert failed to account for store-specific factors (e.g., product mix, clientele income) that could explain higher volumes.
District court admitted the expert’s comparative calculations; Ninth Circuit reviews expert-admissibility decisions for abuse of discretion and affirmed the admission, holding that omitted contextual factors go to weight, not admissibility.

Issue	Hassan's Argument	Government's Argument	Held
Admissibility of expert testimony comparing EAG’s SNAP transaction frequency and dollar volume to other stores	Expert’s calculations are misleading because the expert failed to consider distinguishing factors (product mix, clientele income), so testimony should be excluded	Expert only offered raw comparative calculations; any omission affects credibility/weight, not admissibility	Affirmed: calculations admissible; failure to consider contextual factors goes to weight, not admissibility; no abuse of discretion

United States v. Ruvalcaba-Garcia, 923 F.3d 1183 (9th Cir. 2019) (abuse-of-discretion standard for admitting expert testimony)
United States v. Morales, 108 F.3d 1031 (9th Cir. 1997) (abuse of discretion occurs when decision rests on erroneous legal view or clearly erroneous factual assessment)