United States v. Adame
827 F.3d 637
| 7th Cir. | 2016Background
- Early morning fire at a two-story building in Chicago (Jan. 14, 2012) originated in Blanca Ortiz’s apartment; her neighbor Jimmy Maca died of smoke inhalation.
- Ortiz had recently broken up with Juan Adame; Adame was seen taking Ortiz’s belongings the night before and had a history of controlling behavior toward her.
- Witness Maria Navarette testified Adame drove Ortiz’s Mustang, pumped gas (while she didn’t see the nozzle in the tank), parked near Ortiz’s building, left with a backpack, and returned hours later with garbage bags containing Ortiz’s property.
- Fire investigators found accelerant poured in three locations; forensic testing identified gasoline in one sample and inconclusive results in others.
- Adame made various post-arrest statements (at times denying, at times admitting presence and refusing to explain); historical cell-site analysis placed Adame and Navarette in the general areas consistent with the witness timeline.
- A jury convicted Adame of arson affecting interstate commerce (18 U.S.C. § 844(i)); district court sentenced him to 40 years; Adame appealed raising sufficiency and evidentiary (Daubert, Miranda, Rule 403) challenges.
Issues
| Issue | Plaintiff's Argument (Government) | Defendant's Argument (Adame) | Held |
|---|---|---|---|
| Sufficiency — causation (did Adame pour/ignite gasoline?) | Circumstantial evidence (Navarette’s gas-stop behavior, Adame’s backpack, two-hour absence, return with Ortiz’s items, accelerant found) supports conviction | Navarette did not directly see gasoline in a container or smell it; thus no direct proof he supplied/used gasoline | Guilty verdict supported; circumstantial evidence sufficient to infer Adame pumped, carried, and used gasoline to start fire |
| Sufficiency — commerce element under § 844(i) | Building was leased/rental property (testimony owner leased units) — satisfies interstate-commerce element | Government failed to show substantial effect on interstate commerce | Owner’s testimony that units were leased satisfied the commerce element |
| Admissibility — historical cell-site analysis (Daubert / Rule 702) | Testimony was reliable and corroborated by other evidence; even if error, it was harmless because cumulative | Adame challenged reliability and precision; sought exclusion | Court reviewed de novo, found analysis consistent with precedents; even assuming inadmissible, admission was harmless because cumulative and corroborated by other evidence |
| Admissibility — post-arrest statement (“I didn’t mean to hurt Jimmy”) (Miranda) | Statement was admissible; no timely pretrial suppression motion; record does not show surprise or material variance | Statement was admitted without proper suppression litigation and differed materially from pretrial disclosures, prejudicing defense | Failure to timely move to suppress limits review; record lacks asserted prior phrasing; no reversible error shown |
| Admissibility — cell-phone video admitted to jury room (Rule 403) | Video was admissible, relevant, and not unfairly prejudicial; other evidence overwhelming | Allowing video (and word “fire”) into jury room was unfairly prejudicial and misleading | District court did not clearly abuse discretion; any possible prejudice was harmless given overwhelming other evidence |
Key Cases Cited
- Daubert v. Merrell Dow Pharm., Inc., 509 U.S. 579 (trial courts gatekeep expert reliability)
- Russell v. United States, 471 U.S. 858 (interstate-commerce element analysis in arson/rental contexts)
- United States v. Hill, 818 F.3d 289 (historical cell-site analysis can reliably show general-area presence; expert must avoid overstating precision)
- United States v. Acox, 595 F.3d 729 (timeliness rules for suppressing evidence and raising pretrial motions)
- Naeem v. McKesson Drug Co., 444 F.3d 593 (inadmissible expert testimony harmless if cumulative and corroborated)