United States v. Matias, 707 F.3d 1

Matías was convicted after a nine-day trial in the District of Massachusetts for attempted possession with intent to distribute at least five kilograms of cocaine and sentenced to 20 years' imprisonment plus 10 years' supervised release.
He challenges two trial-related rulings on appeal: admissibility of cash seized from a storage locker and the prosecutor's closing arguments.
DEA agents pursued a cocaine deal with Matías through multiple meetings, culminating in a June 2008 arrest after seeing a large cash payment.
Following the arrest, authorities searched Matías's clothing store and a Sterling storage locker, discovering about $45,000 in cash in the locker, which Matías owned.
Matías admitted ownership of the locker cash and testified that the money had been hidden to hide proceeds from drug trafficking.
The district court admitted the locker cash evidence as relevant to rebut an entrapment defense and to show predisposition to engage in drug trafficking.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether locker cash evidence was relevant to the charged crime.	Matías contends cash from the locker is not probative of the cocaine charge and risks prejudice.	United States argues cash shows predisposition and ability to monetize large drug deals.	Admissible; evidence relevant to predisposition and ability to complete large-scale transactions.
Whether the prosecutor's closing remarks were improper such that they violated due process.	Matías argues the remarks were prejudicial and eclipsed the government's burden.	United States contends remarks were proper, context-dependent, and not coercive.	Not reversible error; remarks viewed in context do not render the trial unfair.

United States v. Valerio, 676 F.3d 237 (1st Cir. 2012) (standard for viewing undisputed facts in light most favorable to verdict)
United States v. Djokich, 693 F.3d 37 (1st Cir. 2012) (relevance and rebuttal of entrapment defenses)
United States v. Polanco, 634 F.3d 39 (1st Cir. 2011) (abuse-of-discretion Review for evidentiary rulings)
United States v. Isler, 429 F.3d 19 (1st Cir. 2005) (prosecution may comment on defendant credibility when defendant testifies)
United States v. Abreu, 952 F.2d 1458 (1st Cir. 1992) (prosecutor may appeal to common sense in closing arguments)
United States v. Moreno, 947 F.2d 7 (1st Cir. 1991) (prosecutor's appeal to common sense is permissible in weighing evidence)
United States v. Glover, 558 F.3d 71 (1st Cir. 2009) (considerations for evaluating prosecutorial misconduct)
United States v. De La Paz-Rentis, 613 F.3d 18 (1st Cir. 2010) (prosecutorial misconduct analysis in closing)
Kirvan, Inc. v. United States, 997 F.2d 963 (1st Cir. 1993) (golden rule arguments generally do not apply to this context)
Obershaw v. Lanman, 453 F.3d 56 (1st Cir. 2006) (context matters in evaluating prosecutorial statements about intelligence)