United States v. Phil Lamont Trent, 863 F.3d 699

Phil Trent was charged in a five-count indictment including heroin distribution resulting in Tyler Corzette’s death; convicted on all counts and sentenced to 300 months.
Two government witnesses, Kyle Hull and Curtis Land, had pleaded guilty to distribution resulting in death and cooperated under plea agreements that included a mandatory minimum sentence and potential government motions to reduce their sentences.
Trent sought to cross-examine Hull and Land about the exact 20‑year mandatory minimum to show bias; the district court allowed impeachment about a "substantial" mandatory minimum but barred specifying the exact length to avoid revealing the sentence Trent himself faced.
Illinois State Police Sgt. James Rieck, who investigated Trent undercover, identified Trent’s voice on recorded phone calls; Trent objected that the government failed to lay proper foundation for the voice ID.
The court permitted Rieck’s voice identification after the government elicited that Rieck had met Trent in person and corroborated the ID with phone contacts, phone records, and contacts saved in Trent’s phone.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether limiting cross-examination to a non‑quantified "substantial" mandatory minimum violated the Sixth Amendment Confrontation Clause	Trent: barring the exact 20‑year figure prevented full exposure of witnesses’ motivations and credibility	Government: specifying the exact sentence would reveal Trent’s potential sentence and mislead jury; "substantial" sufficed to show bias	Court: No constitutional violation; limit reviewed for abuse of discretion and was not an abuse—the jury had sufficient information to assess bias
Whether admitting Sgt. Rieck’s voice identification was improper for lack of foundation	Trent: government failed to establish sufficient foundation for voice ID	Government: Rieck had met Trent in person and recognized his voice; corroborating phone evidence supported ID	Court: No abuse of discretion—minimal familiarity standard met and substantial circumstantial corroboration supported admissibility

United States v. Recendiz, 557 F.3d 511 (7th Cir. 2009) (distinguishes when limits on cross-examination trigger de novo review under Confrontation Clause)
United States v. Sanders, 708 F.3d 976 (7th Cir. 2013) (partial restriction on cross-examination acceptable if defense can expose bias)
United States v. Arocho, 305 F.3d 627 (7th Cir. 2002) (courts may prevent juries from learning information that could cause them to improperly infer sentencing consequences)
Delaware v. Fensterer, 474 U.S. 15 (1985) (Confrontation Clause does not permit unrestricted cross-examination)
United States v. Collins, 715 F.3d 1032 (7th Cir. 2013) (minimal familiarity standard for voice identification)
United States v. Mansoori, 304 F.3d 635 (7th Cir. 2002) (hearing a voice once can suffice for identification)
United States v. Davis, 845 F.3d 282 (7th Cir. 2016) (evidentiary rulings and foundation reviewed for abuse of discretion)