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United States v. Santiago-Perez
666 F.3d 57
1st Cir.
2012
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Background

  • Santiago-Pérez was convicted of attempting to possess with intent to distribute 500+ grams of a controlled substance; conspiracy acquittal.
  • Evidence at trial included Santiago's March 15 Tortola encounter with customs about cash carried by him and companions.
  • Santiago disclosed that the money (about $5,000 his group carried) belonged to him and he had split funds to avoid declaration limits; about $14,000 remained with them.
  • Two days later, a package later shipped from St. Thomas contained over a kilogram of cocaine; law enforcement conducted controlled deliveries and arrested participants, including Santiago.
  • Government introduced evidence including money carried, mailing a cocaine-containing box, and drug-price data; jury convicted on attempted possession, acquitted on conspiracy.
  • Santiago argued the money evidence was inadmissible under Rule 403 due to unfair prejudice; district court admitted it. Appellate court reviews for abuse of discretion.

Issues

Issue Plaintiff's Argument Defendant's Argument Held
Whether money evidence was properly admitted under Rule 403 Santiago argues the money evidence was irrelevant or unfairly prejudicial. Santiago contends the evidence misleads jurors about drug dealing and is unfairly prejudicial. Evidence was relevant; no reversible prejudice; district court did not abuse discretion.

Key Cases Cited

  • United States v. Bayard, 642 F.3d 59 (1st Cir. 2011) (standard of review for evidentiary rulings)
  • United States v. Lugo Guerrero, 524 F.3d 5 (1st Cir. 2008) (unfair prejudice concept in Rule 403 analysis)
  • United States v. Varoudakis, 233 F.3d 113 (1st Cir. 2000) (criminal propensity/prejudice considerations in 403)
  • United States v. Candelaria-Silva, 162 F.3d 698 (1st Cir. 1998) (harmless error considerations in 403 context)
  • United States v. Whitney, 524 F.3d 134 (1st Cir. 2008) (harmless-error framework noted in 403 discussions)
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Case Details

Case Name: United States v. Santiago-Perez
Court Name: Court of Appeals for the First Circuit
Date Published: Jan 19, 2012
Citation: 666 F.3d 57
Docket Number: 10-1776
Court Abbreviation: 1st Cir.