United States v. Frederick Addison, 803 F.3d 916

Undercover Illinois State Police surveilled and videotaped Frederick Addison and two associates conducting multiple crack-cocaine transactions at a suspected drug house in East St. Louis on April 3, 2012.
Video and live narration by Master Sgt. Joseph Beliveau captured hand-to-hand exchanges, stashes behind plywood at an adjacent abandoned house, and recovery of latex gloves containing crack cocaine.
A buyer, James Robinson, was stopped minutes later and found with crack cocaine; he testified he bought a $20 quantity from Addison and identified the transaction on the video.
Officers recovered additional crack cocaine after observing Addison stash and retrieve items; Beliveau also testified that he observed Grinston appear to have a handgun, prompting termination of surveillance and arrests.
At trial Beliveau narrated the video, testified as an expert on crack distribution, and answered cross-examination suggesting he had "never … prosecuted the wrong person."
The jury convicted Addison of possession with intent to distribute and distribution of cocaine base; district court sentenced him to 210 months. Addison appealed, challenging portions of Beliveau’s testimony as improper and prejudicial.

Issue	Addison's Argument	Government/Respondent's Argument	Held
Whether Beliveau’s statement that he had "never prosecuted the wrong person" was improper and violated due process	Testimony was irrelevant and bolstered credibility improperly; undermined right to a fair trial	Defense elicited the testimony on cross-examination; thus any error was invited and waived	Court: Invited-error doctrine applies; no reversal (error invited)
Whether testimony that Grinston appeared to have a gun was irrelevant/prejudicial	Testimony unfairly suggested danger and guilt by association, inflaming jurors	Testimony explained why surveillance ended and was what the witness personally observed	Court: Not preserved as constitutional objection; reviewed for plain error and found no reversible error
Whether testimony that surrounding houses were not drug houses was improper/unduly prejudicial	Testimony improperly encouraged jurors to infer Addison’s conduct was exceptional or dangerous	Testimony provided context about the location and corroborated surveillance observations	Court: Reviewed for plain error; no reversal given overwhelming evidence of guilt
Whether any of the challenged testimony affected substantial rights or caused miscarriage of justice	Testimony cumulatively deprived Addison of a fair trial	Evidence against Addison was overwhelming (video, eyewitness testimony, recovered drugs); proper jury instructions were given	Court: No plain error or miscarriage of justice; conviction affirmed

United States v. Fulford, 980 F.2d 1110 (7th Cir. 1992) (invited-error bars reversal when defendant’s counsel opened the door)
United States v. Hall, 109 F.3d 1227 (7th Cir. 1997) (defendant cannot complain about testimony his counsel elicited)
United States v. Olano, 507 U.S. 725 (1993) (plain-error review framework for unpreserved errors)
Taylor v. Kentucky, 436 U.S. 478 (1978) (presumption of innocence must not be undermined by extraneous evidence)
Kentucky v. Whorton, 441 U.S. 786 (1979) (Taylor limited; fairness depends on totality of circumstances)
United States v. Baker, 655 F.3d 677 (7th Cir. 2011) (plain error affects substantial rights only if it affected the outcome)