United States v. Juana Vela-Salinas, 677 F. App'x 224

Background

Aldo Villarreal and his wife Juana Vela‑Salinas ran a multi‑state drug distribution and money‑laundering operation using a south Texas used‑car business (El Shadai Auto Sales) to disguise proceeds.
Villarreal sourced cocaine and marijuana from Mexico and sent large shipments to buyers in Tennessee and Georgia; shipments ranged from small weekly deliveries to 100–300 kg loads flown to Atlanta.
Co‑conspirators (including buyer Zeeshan Syed, transporter Moises Lopez, and sellers Rodney Reed and Maurice Ferguson) testified that Villarreal arranged and directed large drug transactions and that proceeds were funneled through car purchases, trade‑ins, and structured bank deposits.
A confidential informant purchase of one kilogram triggered a ten‑month investigation, wiretaps (15,248 communications), surveillance, and seizures; many co‑conspirators pleaded and testified for the government.
Villarreal was convicted of conspiracy to distribute ≥5 kg cocaine and ≥100 kg marijuana; both defendants were convicted of conspiracy to commit money laundering. Villarreal got life; Vela‑Salinas received 240 months (20 years). Appeals followed.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Denial of interpreter/translation at a pretrial hearing (due process/plain error)	Gov't: Any error was invited and no prejudice shown; review for plain error.	Villarreal: Lack of interpreter and transcript translation violated due process and affected plea consideration.	No reversible error; defendant invited any error and failed to show prejudice.
Exclusion of defense expert (admission under Rule 701 or Rule 702)	Gov't: Expert did not review defendants' records; failed Rule 702(d) reliability; testimony was specialized so not admissible as lay opinion.	Defendants: Crouch offered admissible lay or expert testimony about used‑car business practices.	Affirmed exclusion: testimony was specialized (Rule 701(c)) and expert lacked reliable application to facts (Rule 702).
Sufficiency of evidence for drug conspiracy conviction	Gov't: Testimony of Syed and Lopez plus corroborating witnesses and wiretaps established agreement, intent, and participation.	Villarreal: Witnesses not credible; evidence insufficient.	Evidence sufficient under Jackson v. Virginia; credibility attacks fail on appeal.
Sufficiency of evidence for money‑laundering conspiracy conviction	Gov't: Structured deposits, large unexplained cash, vehicle purchases with illicit proceeds, and admissions show conspiracy to launder and conceal proceeds.	Defendants: Challenged sufficiency.	Evidence sufficient to prove conspiracy to commit money laundering.
Sentence reasonableness for Vela‑Salinas (procedural/substantive)	Gov't: Guidelines properly calculated; enhancements for base offense level, sophisticated laundering, and obstruction supported.	Vela‑Salinas: Raised perfunctory challenges to procedural and substantive reasonableness.	Sentence affirmed as reasonable and within Guidelines; enhancements and obstruction finding supported.

Key Cases Cited

Puckett v. United States, 556 U.S. 129 (plain‑error standard for unpreserved errors)
Jackson v. Virginia, 443 U.S. 307 (standard for sufficiency of the evidence review)
United States v. Amawi, 695 F.3d 457 (6th Cir. 2012) (abuse‑of‑discretion standard for evidentiary rulings)
United States v. White, 492 F.3d 380 (6th Cir. 2007) (distinguishing expert from lay testimony)
United States v. Adamo, 742 F.2d 927 (credibility determinations for witnesses rest with the jury)
Gall v. United States, 552 U.S. 38 (abuse‑of‑discretion standard for sentencing review)
Rita v. United States, 551 U.S. 338 (reasonableness presumption for within‑Guidelines sentences)
United States v. Prince, 618 F.3d 551 (6th Cir. 2010) (elements of money‑laundering conspiracy)
United States v. Colon, 268 F.3d 367 (6th Cir. 2001) (elements of drug conspiracy)
United States v. Brown, 819 F.3d 800 (waiver and argument‑development principles on appeal)