United States v. Russell Collins, 799 F.3d 554

Defendants Collins, Wilburn, and Brosky were charged in a methamphetamine conspiracy and related counts in the Eastern District of Kentucky; eight other individuals were also named in the superseding indictment and some cooperated with the government.
A six-day trial from May 29, 2012 resulted in verdicts finding Collins and Wilburn guilty on multiple counts, including conspiracy to manufacture and distribute methamphetamine, with Brosky convicted on a single count.
Jury allocated quantities, attributing 500+ grams to Collins and Wilburn and less than 50 grams to Brosky, and the district court sentenced Collins to 324 months, Wilburn to 360 months, and Brosky to 70 months.
The district court later addressed various evidentiary issues on appeal, including destruction of evidence, impeachment, expert testimony, and admission of MethCheck records, ultimately affirming the judgments.
The court affirmed the judgments, addressing multiple challenges to admissibility, trial conduct, and sentencing under federal rules and constitutional standards.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Destruction of evidence and Trombetta/Youngblood standards	Brosky argues destruction of lab equipment deprived due process	Government action destroyed potentially exculpatory or useful evidence	No due process violations; Trombetta/Youngblood not satisfied; district court did not err.
Impeachment of Collins with prior conviction	Rule 609(b) admissibility of stale conviction violated; prejudicial	Impeachment value outweighed prejudicial effect; harmless error	District court erred under Rule 609(b) but such error was harmless given overwhelming evidence.
Admission of Agent O’Neil as expert and hearsay/confrontation issues	Testimony about conversion ratios based on out-of-court statements violated Confrontation/hearsay	Agent qualified; testimony necessary for quantity determination	No plain error; trial court did not abuse discretion; Confrontation/hearsay issues not reversible.
Rule 803(6) MethCheck records as business records; foundation/admissibility	Foundation lacking; custodian not sole authenticator	Part-authentication by custodian plus testifying officers sufficient	District court did not abuse discretion; records admitted.
Sufficiency of evidence to prove 500+ gram conspiracy and drug quantity	Evidentiary record supports 500g+ threshold	Evidence insufficient or improperly attributed; scale of conspiracy disputed	Sufficient evidence supported conspiracy and quantity findings.

Trombetta v. California, 467 U.S. 479 (1984) (due process requires meaningful access to exculpatory evidence when destroyed)
Arizona v. Youngblood, 488 U.S. 51 (1988) (failure to preserve potentially useful evidence requires bad faith or other factors)
United States v. Grenier, 513 F.3d 632 (6th Cir. 2008) (standard for review of suppression of exculpatory evidence)
United States v. Cody, 498 F.3d 582 (6th Cir. 2007) (review of destruction/due process with clear error or de novo standards)
United States v. Meyers, 952 F.2d 914 (6th Cir. 1992) (Rule 609(b) balancing and admission of prior convictions for impeachment)
United States v. Sloman, 909 F.2d 176 (6th Cir. 1990) (factors for Rule 609 balancing; probative value vs prejudice)
United States v. Johnson, 581 F.3d 320 (6th Cir. 2009) (plain error standard in Confrontation Clause/hearsay)
Melendez-Diaz v. Massachusetts, 557 U.S. 305 (2009) (testimonial evidence and confrontation in forensic analysis)
Bullcoming v. New Mexico, 131 S. Ct. 2705 (2011) (confrontation clause and forensic testimony)
Crawford v. Washington, 541 U.S. 36 (2004) (Sixth Amendment confrontation principle)