United States v. Jose Sandoval, 460 F. App'x 552

Defendant-appellant Jose A. Sandoval, an immigration attorney, was convicted of obstructing justice under 18 U.S.C. § 1503 and of suborning perjury related to Perez's document fraud case.
Perez, originally under ICE removal order, faced criminal charges after investigators uncovered fraudulent documents; Sandoval represented her in both immigration and criminal matters.
Najera, a key witness, testified that Sandoval urged him to alter his testimony; Perez and Barrera testified to similar discussions and attempts to influence Najera.
Sandoval visited Najera in jail on February 22, 2009; evidence showed a jail-room meeting and discussions about changing Najera’s testimony and Najera’s counsel.
After discovery of Sandoval’s jail visit, the government’s case shifted from Perez’s document fraud to Sandoval’s alleged interference; Perez later cooperated with the government in Sandoval’s prosecution.
The government sought to admit Garcia’s Rule 404(b) testimony about Sandoval advising Garcia to lie on immigration forms; the district court limited its use to intent and cautioned the jury.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether 404(b) evidence was admissible for intent	Sandoval challenges admissibility of Garcia's prior-act testimony on intent.	Sandoval contends 404(b) evidence is irrelevant to Sandoval’s intent to obstruct.	Yes; admissible to show intent to obstruct.
Whether sufficient evidence showed the prior act occurred	Garcia’s testimony suffices to prove prior act occurred.	Single, uncorroborated, and impeachable witness undermines sufficiency.	Implicit finding of act occurred; sufficient evidence despite credibility concerns.
Whether Garcia’s testimony showed absence of mistake or accident	Evidence supports Sandoval’s absence-of-mistake defense via intent to deceive.	Prior act did not bear on Sandoval’s absence of mistake for the charged conduct.	Garcia’s testimony not probative of absence of mistake; error to admit on this ground.
Whether the Rule 403 balancing supported admission	Probative value on deceitful intent outweighed potential prejudice; time closeness justified admission.	Weak probative value; other means exist; risk of prejudice high.	District court did not abuse discretion; evidence admissible to show intent under 404(b).

United States v. Haywood, 280 F.3d 715 (6th Cir. 2002) (three-step 404(b) framework and abuse-of-discretion review)
United States v. Johnson, 27 F.3d 1186 (6th Cir. 1994) (intent in issue and 404(b) probative value)
United States v. Bell, 516 F.3d 432 (6th Cir. 2008) (probative value and balancing in 404(b) context)
United States v. Matthews, 440 F.3d 818 (6th Cir. 2006) (implicit/explicit findings of prior acts; evidentiary proof)
United States v. Benton, 852 F.2d 1456 (6th Cir. 1988) (similarity and proximity in 404(b) reasoning)
Huddleston v. United States, 485 U.S. 681 (U.S. 1988) (standard for admissibility of evidence of prior acts)