United States v. Jones
918 F. Supp. 2d 1
| D.D.C. | 2013Background
- Jones is charged with Conspiracy to Distribute and Possess with Intent to Distribute five kilograms or more of cocaine and fifty grams or more of cocaine base (21 U.S.C. § 846).
- The government obtained court orders for prospective cell-site data for Jones’s phones covering roughly four months.
- Jones moved to suppress the cell-site data; the court denied the motion on December 14, 2012.
- Jones moved in limine to exclude FBI Special Agent Scott Eicher’s cell-site analysis testimony and reports (filed Jan. 3, 2013).
- The court denies the motion to exclude, finding Eicher qualified and analyzing reliability; it requires modification to avoid unfair prejudice by removing outer arcs in maps.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Admissibility under Daubert of Eicher testimony | Eicher is qualified; analysis is reliable and helps prove location | Pie-wedge method unreliable; could mislead jurors | Admissible; Eicher's testimony allowed |
| Risk of unfair prejudice under Rule 403; use of pie wedges | Maps aid jurors in understanding location; probative value outweighs prejudice | Wedges could mislead about exact location | Prejudice mitigated by removing outer arcs; testimony remains admissible |
Key Cases Cited
- Daubert v. Merrell Dow Pharms., Inc., 509 U.S. 579 (U.S. 1993) (establishes the reliability/relevance standard for expert testimony)
- United States v. Schaffer, 439 F. App’x 344 (5th Cir. 2011) (cell site analysis deemed generally accepted for determining general location)