969 F.3d 819
7th Cir.2020Background
- Aug. 19, 2014: Puerto Rico police attempted to stop Medina; he fired at officers, fled, and abandoned his car. Officers found Medina’s birth certificate and four mail receipts in the vehicle.
- Three receipts were for packages sent to Puerto Rico addressed to Rodolfo Duenas in Milwaukee; postal inspectors flagged suspicious packages from Puerto Rico to Duenas.
- Milwaukee officers intercepted a package containing cocaine; it consisted of ~40 small bags totaling more than 1 kilogram, and Duenas was arrested after accepting delivery.
- Forensic evidence: the intercepted powder tested positive for cocaine; a fingerprint analyst matched three of seven prints inside the package to Medina.
- Medina was tried (bench trial) and convicted of conspiracy to distribute 500 grams or more of cocaine; the district judge found portions of Duenas’s testimony credible despite labeling him as having a "tenuous relationship with the truth," and discounted one questionable mail receipt.
- On appeal Medina argued (1) the witnesses’ testimony lacked credibility as a matter of law, (2) the denial of his judgment of acquittal was erroneous, and (3) the government used false testimony in violation of due process. The Seventh Circuit affirmed.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Sufficiency of the evidence / witness credibility | Medina: Officers and Duenas were not credible; testimony and receipts unreliable, so evidence insufficient | Gov't: Evidence (testimony + fingerprints + physical packages) viewed favorably supports conviction; judge credited reliable portions | Affirmed — evidence sufficient; credibility disputes don’t make testimony impossible as a matter of law |
| Denial of judgment of acquittal | Medina: Renewed claim that evidence insufficient warrants acquittal | Gov't: Standard same as sufficiency review; record supports conviction | Affirmed — denial proper under same deferential standard |
| Due process / alleged false testimony (plain-error review) | Medina: Gov't used perjured testimony by Duenas and an officer about the receipts, affecting fairness | Gov't: Judge largely credited only truthful portions; no basis to infer officer lied and no reasonable likelihood result affected | Affirmed — no plain error; judge did not rely on alleged false portions and outcome not undermined |
Key Cases Cited
- United States v. Wasson, 679 F.3d 938 (7th Cir. 2012) (standard for reviewing sufficiency of the evidence)
- United States v. Carraway, 612 F.3d 642 (7th Cir. 2010) (credibility challenges are deferential on appeal)
- United States v. Conley, 875 F.3d 391 (7th Cir. 2017) (testimony lacks credibility as matter of law only if observation was physically impossible)
- United States v. Hayes, 236 F.3d 891 (7th Cir. 2001) (same standard for impossibility as basis to reject testimony)
- United States v. Johns, 686 F.3d 438 (7th Cir. 2012) (review of denial of judgment of acquittal parallels sufficiency review)
- United States v. Coleman, 914 F.3d 508 (7th Cir. 2019) (plain-error review for unpreserved due-process claims about alleged false testimony)
