United States v. Alejandro Garcia-Lagunas, 835 F.3d 479

Background

Alejandro "Alex" Garcia-Lagunas was arrested in a trailer after surveillance tied him by phone records to several known drug dealers; dealers testified he sold large quantities of cocaine.
Officers found drug-trafficking paraphernalia (large and small scales, vacuum-sealed bag with ~800g white powder that field-tested positive but later tested negative), body armor, small baggies, multiple phones, a revolver, and $600 on Garcia-Lagunas.
Garcia-Lagunas was indicted for conspiracy to distribute 500+ grams of cocaine (tried) and unlawful reentry (pled guilty); jury convicted on the conspiracy charge.
At trial, Detective Orellano (law-enforcement witness) opined — without being qualified as an expert — that "Hispanic drug traffickers" often live modestly because they remit proceeds abroad; government used this to rebut defense theory that Garcia-Lagunas was too poor to be a major dealer.
On appeal the government conceded the stereotyping testimony may be constitutional error; the panel assumed constitutional error and reviewed whether it was harmless beyond a reasonable doubt.
The panel affirmed the conviction (holding the error harmless beyond a reasonable doubt) but vacated and remanded the sentence due to a plain error in calculating Guidelines offense level and remanded for resentencing.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Government’s use of ethnic stereotype (Orellano) — constitutional error and harmlessness	Gov: Even if constitutional error occurred, the error was harmless beyond a reasonable doubt because overwhelming circumstantial and testimonial evidence supported guilt.	Garcia-Lagunas: Stereotype was constitutional error that could have swayed jurors and undermined defense theory; not harmless.	Panel assumed constitutional error and held it harmless beyond a reasonable doubt given dealer testimony, phone records, paraphernalia, and circumstantial evidence.
Admission of immigration-status evidence and interpreter references	Gov: Immigration status and interpreter references were relevant to identity and showing he was the "Alex" referenced by informants.	Garcia-Lagunas: Immigration-status evidence was prejudicial and not probative; interpreter references could paint him as a faker.	Immigration-status testimony was improperly admitted but not plain error (did not affect outcome); interpreter references were admissible for identity and not prejudicial.
Expert disclosure & scope of Detective Collins’s testimony (Rule 16)	Garcia-Lagunas: Government’s Rule 16 notice for Collins was deficient; Collins testified beyond lay competence on SBI lab issues.	Gov: Collins’s testimony was background/contextual; defense was not prejudiced by lack of a fuller summary.	Any Rule 16 defect did not affect substantial rights; Collins’s testimony about field vs. lab tests was admissible as lay opinion grounded in his training/experience; no reversible error.
Sentencing errors — Collins quantity jury instruction (Collins error) and Guidelines calculation	Garcia-Lagunas: District court erred by not instructing jury to find amount attributable to him (Collins) and miscalculated offense level (resulting in higher guideline range).	Gov: No Collins error was plain; even if so, no prejudice; Guidelines minor arithmetic/interpretation issue.	No plain error as to Collins-instruction issue (no substantial-rights effect); plain error found in Guidelines calculation (court sentenced under level 36 though it intended a two-level reduction to 34) — sentence vacated and remanded for resentencing.

Key Cases Cited

Neder v. United States, 527 U.S. 1 (1999) (establishing harmless-error standard for constitutional errors)
Chapman v. California, 386 U.S. 18 (1967) (government bears burden to prove harmlessness beyond a reasonable doubt)
Arizona v. Fulminante, 499 U.S. 279 (1991) (harmless-error framework and review de novo for harmlessness)
United States v. Collins, 415 F.3d 304 (4th Cir. 2005) (jury must determine drug quantity attributable to individual defendant for statutory sentencing thresholds)
Molina-Martinez v. United States, 136 S. Ct. 1338 (2016) (applying presumption of prejudice when defendant is sentenced under an incorrect Guidelines range and received a sentence at the bottom of that range)
United States v. Johnson, 617 F.3d 286 (4th Cir. 2010) (contrast case where erroneously admitted testimony was not harmless due to weak circumstantial proof and witness contradictions)
United States v. Holness, 706 F.3d 579 (4th Cir. 2013) (harmless-error analysis where government’s case was largely circumstantial)