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