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969 F.3d 819
7th Cir.
2020
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Background

  • 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)
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Case Details

Case Name: United States v. Orlando Medina
Court Name: Court of Appeals for the Seventh Circuit
Date Published: Aug 13, 2020
Citations: 969 F.3d 819; 19-1909
Docket Number: 19-1909
Court Abbreviation: 7th Cir.
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    United States v. Orlando Medina, 969 F.3d 819