United States v. Quiles-Davila
6:24-cr-00233
M.D. Fla.May 8, 2025Background
- The defendant, Dariel Javier Quiles-Davila, a police officer, is charged with one count of receipt of child pornography in violation of 18 U.S.C. § 2252A(a)(2), allegedly occurring on October 17, 2023.
- The government alleges Quiles-Davila exchanged sexual communications and images with a minor via Snapchat, and repeated communications continued between October 2023 and April 2024.
- Law enforcement discovered explicit content and significant follow-up interactions during their investigation.
- Quiles-Davila filed a motion in limine under Federal Rules of Evidence 403 and 404(b) to exclude evidence of communications and related acts after the charged offense date.
- The government opposed, arguing that this evidence is intrinsic to the chain of events relating to the charge, and that even if subject to 404(b), it is admissible for proper purposes.
- The court heard arguments on May 6, 2025, and ruled on the motion on May 8, 2025.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Admissibility of post-offense communications under Rule 404(b) | Evidence is intrinsic, not extrinsic; completes story of the crime | Evidence is extrinsic and should be excluded under 404(b), improper notice | Evidence is intrinsic, not subject to 404(b)—admissible |
| Rule 403 Balancing | Evidence is highly probative for motive, plan, identity, absence of mistake, etc. | Probative value is substantially outweighed by unfair prejudice, confusion, waste | Evidence's probative value not outweighed; not excluded under 403 |
| Government’s notice under Rule 404(b) | Notice duty does not apply if evidence is intrinsic | Government notice insufficient under 404(b) for extrinsic acts | Not applicable because evidence is intrinsic |
| Limiting Instructions | Suggests limiting instructions may mitigate prejudice | Seeks to avoid prejudice to jury | Court will consider instructions if requested at trial |
Key Cases Cited
- United States v. McLean, 138 F.3d 1398 (11th Cir. 1998) (establishing district court’s broad discretion over evidentiary rulings)
- United States v. Jernigan, 341 F.3d 1273 (11th Cir. 2003) (recognizing district court’s evidentiary rulings are reviewed for abuse of discretion)
- United States v. Elkins, 885 F.2d 775 (11th Cir. 1989) (Rule 403 should generally favor admissibility of relevant evidence)
- United States v. Williford, 764 F.2d 1493 (11th Cir. 1985) (intrinsic evidence is admissible to complete story of the crime)