United States v. Landron-Class
696 F.3d 62
| 1st Cir. | 2012Background
- Landrón-Class was convicted in the District of Puerto Rico for participating in a prescription-drug distribution scheme.
- Government witness Dr. José Vázquez-Senti testified he issued thousands of medically unnecessary prescriptions to landrón-class and others.
- Appellant faced trial after rejecting a favorable plea offer and asserting factual innocence.
- Evidence included wiretaps, recorded calls, patient lists provided by appellant, and DEA surveillance.
- District court admitted testimony about co-defendants' guilty pleas; court later held the error harmless on appeal.
- Appellant challenged voir dire, evidentiary rulings, Jencks material, denial of Rule 29 motion, and sentencing calculations.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Admission of co-defendants’ guilty pleas | Landrón-Class argues error in admitting pleas of Vázquez-Senti’s co-defendants | Landrón-Class contends the evidence was probative of guilt by association | Harmless error; evidence viewed as a whole supported guilt |
| Jencks material (ROI/rough notes) | Jencks material should be turned over | ROIs not Jencks statements; rough notes not admissible | District court did not abuse discretion; ROIs not Jencks material; rough notes not required |
| Cross-examination of Vázquez-Senti | Defense should be allowed to probe dismissed charges and cooperation terms | Limiting cross-examination prevented prejudice and confusion | Properly limited; evidence of motive/bias adequately conveyed to jurors |
| Rule 29 motion (sufficiency of evidence) | Evidence insufficient to sustain drug quantity | Record supported defendant’s connection to lists and drug quantities | No error; substantial evidence tied appellant to the prescription lists and conspiracy |
| § 3553(a) cooperation consideration | Cooperation cannot be weighed without a 5K1.1 motion | Court may consider cooperation as a § 3553(a) factor regardless of 5K1.1 motion | Court may consider cooperation under § 3553(a); no reversible error in sentencing decision |
Key Cases Cited
- United States v. Díaz, 670 F.3d 332 (1st Cir. 2012) (used for standard of review and favorable-view of facts)
- United States v. Mare, 668 F.3d 35 (1st Cir. 2012) (abuse of discretion review; harmless-error framework)
- United States v. Walker, 665 F.3d 212 (1st Cir. 2011) (harmless error and total-evidence approach)
- United States v. Ofray-Campos, 534 F.3d 1 (1st Cir. 2008) (prohibition on implying guilt by association when co-defendant guilty plea not in trial)
- United States v. Dworken, 855 F.2d 12 (1st Cir. 1988) (guilt-by-association concerns in joint trials)
- United States v. Gonzalez-Melendez, 570 F.3d 1 (1st Cir. 2009) (Jencks material definitions; independent investigation requirement)
- United States v. Dunbar, 553 F.3d 48 (1st Cir. 2009) (harmless-error standard for improperly admitted evidence)
- United States v. Gall, 552 U.S. 38 (S. Ct. 2007) (reasonable appellate review of sentencing decisions (Gall guidance))
- Kimbrough v. United States, 552 U.S. 85 (S. Ct. 2007) (recognizes court discretion to vary based on policy disagreements with guidelines)