United States v. Goris, 876 F.3d 40

DEA conducted an undercover sting in 2014; Goris negotiated to buy 1–5 kg of cocaine and insisted on testing a sample before larger purchase.
On August 14, 2014, Goris removed a brick (a dummy kilogram placed by the agent) from the agent’s car at a home-improvement store and was arrested; indicted for attempting to possess 500 grams or more of cocaine with intent to distribute (21 U.S.C. § 841(a)(1)).
Government produced recorded conversations, including the August 14 recording; Goris moved under Rule 16 for access to the original recording file and related software, alleging possible editing/manipulation.
The district court denied the discovery request on the ground Goris failed to show materiality and alternatively because the requested materials were proprietary; Goris renewed the motion before trial but denial stood.
At an evidentiary hearing, Goris’s expert suggested editing due to moments of zero background noise but lacked familiarity with the recording system; government affidavit explained the digital, non-modifiable web-based system and signal-related audio gaps.
Jury convicted Goris; he appealed arguing improper denial of discovery and erroneous jury instructions regarding drug-quantity element (500 grams) that imposed the mandatory five-year minimum.

Issue	Plaintiff's Argument (Gov't)	Defendant's Argument (Goris)	Held
Denial of Rule 16 discovery of original recording and recording system	Denial proper because defendant failed to show materiality; gov’t affidavit showed files couldn’t be edited	Sought original file and software to test claim recording was edited; argued material to prepare defense	Affirmed — district court did not abuse discretion; defendant failed to show discovery would have significantly altered proof in his favor
Jury instructions on drug-quantity element (≥500 g)	Instructions, read as a whole, correctly required proof beyond a reasonable doubt that Goris knew offense involved ≥500 g	Claimed two isolated sentences undercut requirement that jury find attempted possession of ≥500 g beyond a reasonable doubt	Affirmed — instructions taken in context sufficiently and repeatedly conveyed the required burden of proof

United States v. Ross, 511 F.2d 757 (5th Cir. 1975) (materiality requires indication disclosure would significantly alter quantum of proof in defendant's favor)
United States v. Carrasquillo-Plaza, 873 F.2d 10 (1st Cir. 1989) (defendant bears burden to show materiality under Rule 16)
United States v. Correa-Alicea, 585 F.3d 484 (1st Cir. 2009) (abuse-of-discretion review for Rule 16 rulings)
United States v. Rosario-Peralta, 199 F.3d 552 (1st Cir. 1999) (denial proper where request rests on speculation)
United States v. Pennue, 770 F.3d 985 (1st Cir. 2014) (jury instructions must be read as a whole when assessing whether they misled the jury)