United States v. Rodrigo Macias-Farias
2013 U.S. App. LEXIS 2693
6th Cir.2013Background
- Macias-Farias was convicted at trial on two drug-trafficking counts tied to a large marijuana shipment.
- DEA interdicted about 1,600 pounds of marijuana Feb. 10; a coordinated sale plan involved multiple co-conspirators.
- Lacefield cooperated with the DEA, leading to a Feb. 18 meeting at a Louisville Rite Aid regarding transfer of drugs.
- Amber Babor was later identified as another participant; her car contained about 100 pounds of marijuana.
- A larger seizure occurred Feb. 25 when agents found approximately 3,766 pounds of marijuana in a truck tied to the plan.
- Macias-Farias testified at trial, denying involvement; conviction followed and he was sentenced to 320 months.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Brady/Confrontation issues from witness testimony | Macias-Farias argues Brady violation and Confrontation Clause burden | Macius-Farias contends suppression and confrontation error | No reversible Brady or confrontation error; remand unnecessary for these issues |
| Obstruction of justice enhancement at sentencing | Government supports enhancement based on perjury; lists statements | District court failed to identify perjurious statements and apply Dunnigan elements | Remand required to make specific perjury findings and apply §3C1.1 properly |
Key Cases Cited
- United States v. Dunnigan, 507 U.S. 87 (1993) (two-step perjury findings required for obstruction enhancement)
- United States v. Bazazpour, 690 F.3d 796 (6th Cir. 2012) (remand when perjury findings are not specific)
- United States v. Sassanelli, 118 F.3d 495 (6th Cir. 1997) (courts may rely on government lists only if independent findings accompany them)
- United States v. Lawrence, 308 F.3d 623 (6th Cir. 2002) (vacate obstruction enhancement for lack of perjury findings)
- United States v. McRae, 156 F.3d 708 (6th Cir. 1998) (rejection of enhancement without specific perjury findings)