United States v. Jwuan Moreland, 703 F.3d 976

Nine defendants convicted by jury of conspiracy to distribute methamphetamine and marijuana; some charged additionally with firearms.
Evidence included wiretaps supporting breadth of conspiracy; defense argued wiretap was unnecessary given other investigative methods.
Defendants challenged jury selection and potential cross-section issues due to excused jurors for hardship; asserted violations of Jury Selection and Service Act and Rule 43.
Experts testified that a DEA agent decoded drug codes, with concerns about dual lay/expert roles and potential jury overawing.
Appeals addressed credit-based conspirator status (Phipps/Weir), suppression issues, sentence-enhancement decisions (life sentences for repeat offenses), and minimal-participant claims (Smith).
Judgments affirmed on all counts; some defendants faced life sentences under 21 U.S.C. § 841(b)(1)(A) after multiple drug felonies.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether wiretaps were necessary given other investigative methods.	Government contends wiretaps were essential to prove breadth and leaders.	Defendants argue other methods sufficed; affidavits不足以 show necessity.	Wiretap necessity upheld where other methods unlikely to yield essential evidence.
Whether excusing jurors pre-trial violated Rule 43 or the Act.	Defendants contend biased jury composition; challenged excusals.	Courts allowed pre-impanelment excusal for hardship; no systemic exclusion shown.	No reversible error; no improper voir dire procedures established.
Whether dual-role expert/lay testimony violated reliability concerns.	Agent’s dual role risked undue weight on expert testimony.	Dual roles explained and curative limiting instruction given.	No reversible error; instructions adequate to mitigate risk.
Whether Phipps and Weir were conspirators; impact on conspiracy conviction.	Evidence of credit-based drug sales and resale implied conspiracy.	Retail buyers may resell without joining conspiracy; no mutual agreement.	Convictions affirmed; evidence supported conspiracy inference, though some doubt acknowledged.
Whether Smith received undue minimal-participant discount.	Minor-participant discount warranted given role.	Defendant was not minimal participant; discount improper.	Smith did not qualify for minimal-participant reduction; she remained a major participant.

United States v. Nunez, 673 F.3d 661 (7th Cir. 2012) (relational-contract approach in drug conspiracies; caution against laundry-list tests)
United States v. Lechuga, 994 F.2d 346 (7th Cir. 1993) (contract vs conspiracy; credit/fronting as inference of conspiracy)
United States v. Boidi, 568 F.3d 24 (1st Cir. 2009) (multifactor tests discouraged; caution against loose factor lists)
Old Chief v. United States, 519 U.S. 172 (1987) (prior convictions redaction to limit prejudice)