United States v. Fields
2011 U.S. App. LEXIS 22100
| 1st Cir. | 2011Background
- Fields was charged with distribution of cocaine base within 1000 feet of a school and convicted in 2008.
- A sting operation on Oct 4, 2007 used a cooperating witness to arrange a purchase of about $300 of cocaine base.
- The transaction occurred about 700 feet from a public school; 5.84 grams of cocaine base were sold to the informant.
- Eye-witness identification by three officers and voice recordings plus cell phone records tied Fields to the sale; the CW did not testify due to death.
- Fields argued at trial that he was not identified as the seller; defense pointed to inconsistencies and lack of corroborating evidence.
- On appeal, Fields raises two issues: (i) whether the trial court erred by not defining reasonable doubt in jury instructions, and (ii) whether certain prosecutorial testimony about the sting improperly bolstered witnesses.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether failure to define reasonable doubt requires reversal | Fields contends no definition was given and that affects juror understanding. | Fields asserts lack of definitional guidance undermines verdict. | No reversal; reasonable doubt need not be defined. |
| Whether targeting testimony constitutes improper bolstering | Fields argues testimony about the sting shows prior knowledge and bolsters witnesses. | Fields argues such questioning reveals improper basis for investigation. | Harmless error; extensive independent evidence of guilt rendered any error non-prejudicial. |
Key Cases Cited
- United States v. Wallace, 461 F.3d 15 (1st Cir. 2006) (no need to define reasonable doubt)
- United States v. Ademaj, 170 F.3d 58 (1st Cir. 1999) (no definition required)
- United States v. Rodriguez-Cardona, 924 F.2d 1148 (1st Cir.) (reasonable doubt standard)
- United States v. Olmstead, 832 F.2d 642 (1st Cir. 1987) (self-evident meaning of reasonable doubt)
- Victor v. Nebraska, 511 U.S. 1 (Supreme Court 1994) (Constitutional stance on defining reasonable doubt)
- United States v. Colón-Díaz, 521 F.3d 29 (1st Cir. 2008) (discourages revealing reasons for investigation)
- United States v. Hicks, 575 F.3d 130 (1st Cir. 2009) (harmless error standard in similar context)
- United States v. Benitez-Avila, 570 F.3d 364 (1st Cir. 2009) (precedent on bolstering and related objections)
- United States v. Lamberty, 778 F.2d 59 (1st Cir. 1985) (historical treatment of evidence and credibility)