United States v. Miguel Manriquez
713 F. App'x 885
| 11th Cir. | 2017Background
- Manriquez was convicted by a jury of conspiracy to distribute and possess with intent to distribute 50+ grams of methamphetamine arising from a prison-based trafficking scheme.
- Cooperating witness George O’Leary identified a supplier known by aliases “Miguel,” “Angel,” and “Three Eyes,” who coordinated deals from a Georgia prison using a phone; investigators identified Jose Arroyo as a coordinator and arranged wiretaps and controlled buys.
- Witness Yesenia Montufar and O’Leary testified that Arroyo introduced them to “Miguel/Angel/Three Eyes”; intercepted calls referenced Calhoun State Prison and the name Carmen Manriquez.
- Investigators located Miguel Manriquez incarcerated at Calhoun; booking photos showed a Virgin Mary back tattoo labeled “Three Eyes.” Montufar testified the photo matched a tattoo-image she had received from “Angel.”
- Manriquez moved for judgment of acquittal arguing the government failed to prove he was the voice on the calls and failed to prove his participation in the conspiracy; he also moved to suppress the belatedly disclosed booking photograph of his back tattoo.
- The district court denied acquittal and denied suppression; the Eleventh Circuit affirmed.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Sufficiency of evidence to identify defendant as "Miguel/Angel/Three Eyes" | Gov't presented enough circumstantial evidence to identify Manriquez as the speaker | Manriquez: witnesses could not identify him in court or directly tie his voice to the calls | Affirmed — circumstantial evidence (aliases, prison location, tattoo, contact name) permitted a reasonable juror to find guilt beyond a reasonable doubt |
| Sufficiency of evidence of conspiracy participation (beyond voice ID) | Gov't must prove he joined and knowingly participated in the conspiracy | Manriquez: no evidence he possessed or handled methamphetamine | Affirmed — conspiracy conviction sustainable without proof of possession where evidence shows agreement, knowledge, and voluntary joining (calls, supply role) |
| Exclusion of belatedly disclosed booking photo (discovery violation) | Photo disclosed 11 days before trial, violating court order; should be suppressed | Gov't: tardy by 3 days only; defense had time; no substantial prejudice and defense elected to proceed | Affirmed — district court did not abuse discretion; no substantial prejudice shown, so exclusion not required |
Key Cases Cited
- United States v. Davis, 854 F.3d 1276 (11th Cir. 2017) (standard of review on sufficiency of the evidence)
- United States v. Mendez, 528 F.3d 811 (11th Cir. 2008) (circumstantial evidence requires reasonable inferences, not speculation)
- United States v. Mieres-Borges, 919 F.2d 652 (11th Cir. 1990) (direct and circumstantial evidence afforded equal weight)
- United States v. Barron-Soto, 820 F.3d 409 (11th Cir. 2016) (elements required to sustain a §846 conspiracy conviction)
- United States v. Rivera, 944 F.2d 1563 (11th Cir. 1991) (reversal for discovery violations requires showing effect on substantial rights)