United States v. Branea Bryant
23-3751
6th Cir.Mar 21, 2025Background
- Branea Bryant was involved in a large drug-trafficking operation in Cleveland, collaborating with her boyfriend, brother, and others, including members of the Heartless Felons gang.
- She aided in transporting and selling fentanyl, cocaine, and methamphetamine, and laundered over $150,000 through a sham company, ADF3 Investments, which owned properties used for drug transactions.
- Bryant used proceeds from the drug sales to support an extravagant lifestyle, spending tens of thousands on luxury goods and vehicles.
- She was convicted by a jury of multiple counts related to drug trafficking and money laundering and sentenced to 290 months in prison.
- On appeal, Bryant challenged several evidentiary rulings made by the district court, including the admission of certain witness testimony and the refusal to disclose a confidential informant.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Dual expert/lay witness role instructions | The jury was not properly instructed on Agent Platt's dual role, potentially crediting fact testimony as expert. | Instructions were proper and sufficient. | District court did not err; instructions were adequate. |
| Admissibility of Platt's voice identifications | Platt was not qualified as an expert for voice IDs; identifications were improper. | Platt had personal knowledge sufficient for admissibility. | District court did not err; identifications admissible. |
| Admission of co-conspirators' statements | The prosecution failed to show Bryant was a co-conspirator. | Sufficient evidence linked Bryant to conspiracy. | District court did not err; statements properly admitted. |
| Nondisclosure of confidential informant | Disclosure of Source #1's identity could affect credibility and the jury's view. | Source #1's identity irrelevant; did not testify or provide direct evidence. | District court did not err; nondisclosure was proper. |
Key Cases Cited
- Fed. R. Evid. 702 (expert testimony admissibility—statutory reference)
- United States v. Barron, 940 F.3d 903 (6th Cir. 2019) (permissibility and required instructions for dual expert/lay witness testimony)
- United States v. Gardner, 32 F.4th 504 (6th Cir. 2022) (admissibility of lay voice identifications)
- Bourjaily v. United States, 483 U.S. 171 (1987) (admissibility of co-conspirator statements)
- Roviaro v. United States, 353 U.S. 53 (1957) (framework for confidential informant disclosure)