United States v. Casanova, 886 F.3d 55

On April 30, 2013 Darian Thomson was shot in the head but survived; police later linked the attack to a group associated with Raymond Jeffreys.
Jaquan Casanova (defendant) was alleged to have driven with others that evening and to have exited the car and shot Thomson; a palm print from a straw wrapper in the car was identified by the government as Casanova’s.
Co‑defendant Raymond Jeffreys ran a criminal enterprise (sex trafficking, drugs); other witnesses (including an immunized witness, Harris, and a prostitute, Lungelow) placed Casanova at the scene and testified Jeffreys ordered the attack because Thomson was a suspected informant.
Casanova was indicted on multiple counts including witness tampering by attempting to kill (18 U.S.C. § 1512(a)(1)(C)) and making false statements (18 U.S.C. § 1001); he was convicted of witness tampering and false statements, acquitted of conspiracy, and sentenced to 28 years.
On appeal Casanova raised three unpreserved claims: (1) inadequate voir dire on racial bias (no individual questioning of all jurors), (2) prejudicial expert testimony overstating fingerprint reliability, and (3) admission of testimony about Jeffreys’s violent treatment of prostitutes under Rule 403.

Issue	Casanova's Argument	Government's Argument	Held
Whether the court violated the Sixth Amendment by not individually questioning all prospective jurors about racial bias	Court should have individually voir dired each juror after evidence one juror revealed bias at sidebar	Group voir dire was adequate; trial court individually questioned any juror who signaled bias and excused biased jurors	No plain error; group voir dire was constitutionally sufficient under controlling precedent (Parker)
Whether expert testimony overstated fingerprint identification reliability and was therefore prejudicial	Fingerprint expert implied an effectively zero false‑positive rate, misleading jury and prejudicing Casanova	Expert acknowledged no accepted statistical database and said error rate was not zero; testimony fit for cross/redirect	No plain error; testimony did not falsely claim zero error rate and was properly tested by cross-examination
Whether testimony about Jeffreys’s abuse of prostitutes should have been excluded under Rule 403 as unduly prejudicial	Testimony about Jeffreys’s violence was more prejudicial than probative and unfairly spilled over to Casanova	Testimony was probative of Jeffreys’s motive to silence informants; little spillover and jury differentiated roles; no limiting instruction was sought	No plain error; admission was not an abuse of discretion under Rule 403

United States v. Parker, 872 F.3d 1 (1st Cir.) (group voir dire can suffice for race‑bias inquiry)
Mu’Min v. Virginia, 500 U.S. 415 (1991) (trial court not required to question individual jurors on all experiences that might lead to racial bias)
United States v. Gelin, 712 F.3d 612 (1st Cir. 2013) (voir dire review standard: abuse of discretion)
United States v. Espinal‑Almeida, 699 F.3d 588 (1st Cir. 2012) (plain‑error standard for unpreserved claims)
United States v. Delgado‑Hernández, 420 F.3d 16 (1st Cir. 2005) (plain‑error framework)
United States v. Hosseini, 679 F.3d 544 (7th Cir.) (group voir dire ordinarily adequate even in race‑sensitive cases)
United States v. Ford, 839 F.3d 94 (1st Cir. 2016) (standard of review for preserved evidentiary objections)
United States v. Almeida, 748 F.3d 41 (1st Cir. 2014) (plain‑error review for unpreserved evidentiary objections)
United States v. Van Horn, 277 F.3d 48 (1st Cir. 2002) (reciting standard of reviewing facts in light most favorable to verdict)
United States v. Pena, 586 F.3d 105 (1st Cir.) (latent fingerprint expert testimony routinely admitted)