United States v. Alfonso Torres-Chavez
744 F.3d 988
| 7th Cir. | 2014Background
- Torres-Chavez was convicted by jury on seven counts relating to cocaine conspiracy and distribution; district court sentenced him to 168 months and five years’ supervised release.
- Lucatero, a co-conspirator turned government witness, testified about prior uncharged drug transactions with Torres-Chavez and the two’s trusting relationship.
- The district court admitted Lucatero’s testimony under Rule 404(b)(2) to prove relationship and did so with a limiting instruction.
- Recorded telephone calls linked Guero to Torres-Chavez via multiple voice identifications and airport flight records were offered as supplementary corroboration.
- Torres-Chavez moved for acquittal post-trial challenging the sufficiency of the identification evidence and later sought relief based on juror voir dire statements; the district court denied both; the Seventh Circuit affirmed both the evidentiary rulings and the acquittal denial.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether 404(b) evidence admissible to prove relationship (not propensity). | Torres-Chavez argues the other-acts evidence was insufficient. | Torres-Chavez contends the third prong (sufficiency) failed. | No abuse of discretion; admissible and sufficient. |
| Whether identification of Guero from voice and flight records proves Torres-Chavez as Guero beyond reasonable doubt. | Government identified Guero via multiple witnesses and records. | Identification evidence should be insufficient. | Rule 29 affirmed; rational jury could convict. |
| Whether juror post-verdict statements about following instructions show bias; admissibility under Rule 606(b). | Statements prove bias invalidating the verdict. | Juror statements should be admitted to show bias. | District court did not err; statements inadmissible; no basis for new trial. |
Key Cases Cited
- Jackson v. Virginia, 443 F.3d 307 (U.S. 1979) (standard for sufficiency of evidence for conviction)
- Remmer v. United States, 347 U.S. 227 (U.S. 1954) (presumption of prejudice from outside jury influences)
- Tanner v. United States, 483 U.S. 107 (U.S. 1987) (purpose of Rule 606(b) protections for deliberations)
- United States v. Reese, 666 F.3d 1007 (7th Cir. 2012) (four-part Rule 404(b) admissibility test)
- United States v. DiDomenico, 78 F.3d 294 (7th Cir. 1996) (evidentiary standards for sufficiency under Rule 29)