United States v. Garcia, 646 F.3d 1061

In 2009, Minneapolis police investigated Garcia for meth distribution; Morales arranged meetings and a sample was given to Morales that tested positive for meth.
On Nov 24, Garcia met Morales in a restaurant parking lot; surveillance captured discussion of sources, costs, and purity; Garcia rode in the Dodge Dakota that officers later identified.
Dec 2, Morales arranged a controlled buy at Garcia’s apartment building; Garcia transferred 25.3 grams of meth to Morales; Garcia and Maldonado resided in the same building.
Dec 10, Rodriguez, another suspect, bought meth from Garcia/Maldonado at a Taco Bell lot; subsequent sale occurred at a K-Mart parking lot with a second transfer.
Cell phone records showed 279 calls between Maldonado and Rodriguez between Nov 27 and Dec 22; a federal superseding indictment charged conspiracy and distribution counts.
Maldonado and Garcia moved to suppress statements; the district court denied; trial proceeded with juror contamination concerns raised and resolved mid-trial.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Sufficiency of Garcia evidence for conspiracy and distributions	Garcia participated in November 24 conspiracy and December 2/10 distributions	Insufficient proof of Garcia’s presence and involvement in key transactions	Sufficient evidence supports conspiracy and distribution convictions
Maldonado suppression of phone-number evidence from December 10 stop	Evidence admissible; no Fourth Amendment error	Request for phone number exceeded stop scope; Miranda issues	Within scope of Terry stop; no plain error; admissible
Maldonado sufficiency for conspiracy to distribute 50+ grams	Maldonado knowingly joined conspiracy and quantity could be attributed to him	Not enough proof of Maldonado’s knowing participation or 50+ gram quantity	Sufficient evidence Maldonado knowingly joined and conspiracy involved at least 50 grams
Jury contamination and denial of new trial	Contamination allegations require mistrial or new trial	Juror discussions did not taint the trial; credibility of jurors matters	District court did not abuse its discretion; no new trial warranted

United States v. Moran, 612 F.3d 684 (8th Cir. 2010) (elements of conspiracy to distribute methamphetamine)
United States v. Yarrington, 634 F.3d 440 (8th Cir. 2011) (sufficiency standard for jury verdicts)
United States v. Scofield, 433 F.3d 580 (8th Cir. 2006) (standard for reviewing sufficiency of evidence)
United States v. Aguilera, 625 F.3d 482 (8th Cir. 2010) (evidence of drug distribution and conspiracy considerations)
United States v. Salcedo, 360 F.3d 807 (8th Cir. 2004) (government statements and later use of statements at trial)
Berkemer v. McCarty, 468 U.S. 421 (1984) (identity questions during Terry stops permissible within scope)
Hayes v. Florida, 470 U.S. 811 (1985) (fingerprinting contexts and scope of investigative detentions)
Maryland v. Shatzer, 559 U.S. 98 (2010) (noncustodial detention does not trigger Miranda custody analysis)
Hiibel v. Sixth Judicial Dist. Court, 542 U.S. 177 (2004) (identity information during stops)
Littrell, 439 F.3d 875 (8th Cir. 2006) (conspiracy quantity attribution for reasonably foreseeable acts)
Jimenez v. United States, 487 F.3d 1140 (8th Cir. 2007) (inference in proving conspiracy participation)