United States v. Sanabria
2011 U.S. App. LEXIS 14648
| 1st Cir. | 2011Background
- Morales Sanabria, aka El Chapo, was convicted on multiple drug trafficking counts for three shipments from the Dominican Republic to Puerto Rico between 2006 and 2007.
- The government's evidence primarily rested on three cooperating witnesses (Santana, Ureña, Gómez) who identified Morales as El Chapo and facilitated the drug deliveries.
- Rosario testified Morales used the black TrailBlazer; defense cross-examination sought to prove intimidation by law enforcement to impeach Rosario, but the court limited this line of inquiry.
- Morales challenged trial rulings: exclusion of Agent Ortiz's post-arrest description of El Chapo, limitation on cross-examining Rosario, and admission of Muñoz's lay opinion about Morales's credibility.
- The district court denied relief on these points, Morales was convicted and sentenced to fifty years on each count, to run concurrently, with a $420,000 forfeiture judgment.
- The First Circuit vacated and remanded for a new trial, finding cumulative evidentiary errors prejudicial to Morales.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Exclusion of Ortiz testimony | Ortiz description impeaches Santana; Ortiz testimony should be admitted. | Evidence is collateral; collateral issue rule bars extrinsic proof. | Abuse of discretion; error recognized as part of cumulative prejudice. |
| Limitation on Rosario cross-examination | Cross-examination should probe intimidation and prior statements to impeach Rosario. | Cross-examination restricted appropriately as scope and lack of oath. | Abuse of discretion; limitation contributed to cumulative error. |
| Admission of Muñoz's lay opinion | Muñoz's belief about Morales's innocence assists jury understanding. | Lay opinion on final issue is improper under Rule 701. | Abuse of discretion; improper lay opinion admitted. |
| Cumulative error and new trial | Aggregate errors require new trial under cumulative error doctrine. | Individual errors are harmless when viewed separately. | Vacate judgment and remand for a new trial due to cumulative errors. |
Key Cases Cited
- United States v. Cruz-Rodríguez, 541 F.3d 19 (1st Cir. 2008) (collateral issue rule governing admissibility of extrinsic evidence)
- Delaware v. Van Arsdall, 475 U.S. 673 (U.S. Supreme Court 1986) (Confrontation Clause; limits on cross-examination to show witness bias)
- United States v. Martínez-Vives, 475 F.3d 48 (1st Cir. 2007) (limits on cross-examination for bias; speculative grounds require foundation)
- United States v. Flores-de-Jesús, 569 F.3d 8 (1st Cir. 2010) (harmless-error standard for evidentiary rulings in the non-constitutional context)
- United States v. Meises, 645 F.3d 5 (1st Cir. 2011) (standard for harmlessness in cumulative-error review)
- Sepúlveda, 15 F.3d 1161 (1st Cir. 1993) (cumulative-error framework for evaluating trial errors)
- Pettijohn v. Hall, 599 F.2d 476 (1st Cir. 1979) (identification evidence importance in guilt determinations)
- United States v. Sisto, 534 F.2d 616 (5th Cir. 1976) (prior statements as impeachment material may be admissible)