United States v. Scott Lewis, 641 F.3d 773

Defendants Scott Lewis, Vernon Williams, and Lavoyce Billingsley were charged in the Northern District of Illinois with conspiracy to possess cocaine with intent to distribute and, for each, firearm offenses under 18 U.S.C. § 924(c); Billingsley also faced a felon-in-possession count.
The government’s sting operation was led by ATF Agent Gomez as an undercover operative “Loquito,” involving recorded and unrecorded meetings and multiple recorded phone conversations.
Evidence showed plans to raid a stash house and steal 15–20 kilograms of cocaine, with weapons discussed and shown during a pre-arrest car meeting.
Key physical evidence included a recovered firearm from Billingsley, gloves and do-rags from the defendants, and post-arrest statements by Lewis and Billingsley.
The district court admitted some prior convictions and excluded others, limited certain cross-examination questions, and handled hearsay and completeness challenges during trial.
A jury convicted Lewis and Williams on § 924(c) and Billingsley on § 846 and § 924(c); Billingsley also was convicted of felon-in-possession; sentences included mandatory consecutive terms under § 924(c).

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the evidence sufficed to convict Lewis and Williams under § 924(c).	Gomez’s firearm testimony and the conspiracy evidence support § 924(c).	Credibility problems with Gomez and lack of reliable gun involvement negate foreseeability or possession.	Yes; evidence could sustain conviction despite credibility issues.
Whether Lewis’s entrapment and coercion defenses negate § 846 or § 924(c).	Predisposition and lack of coercion support liability.	Entrapment and coercion defenses negate the government’s theory.	No; the evidence supported predisposition and lack of coercion beyond reasonable doubt.
Whether evidentiary rulings (prior convictions, jailhouse statement, Bayless cross-examination, and completeness) were proper.	Prior convictions and Bayless testimony were properly admitted; completeness not triggered.	Some rulings violated Rule 404(b), Rule 804(b)(3), and the completeness doctrine.	Rulings were within discretion; no reversible error identified.
Whether the mandatory consecutive sentence under § 924(c) was proper given other mandatory minimums.	Consecutive § 924(c) sentence authorized by circuit precedent.	Second Circuit approach prohibits additional consecutive term when other mandatory minimums apply.	Proper; Seventh Circuit approves mandatory consecutive sentence under § 924(c).

United States v. Gorman, 613 F.3d 711 (7th Cir. 2010) (sufficiency review; credibility issues fall to jury)
United States v. Carrillo, 435 F.3d 767 (7th Cir. 2006) (sufficiency of § 924(c) elements)
United States v. McLee, 436 F.3d 751 (7th Cir. 2006) (knowledge/foreseeability for § 924(c))
United States v. Easter, 553 F.3d 519 (7th Cir. 2009) (consecutive § 924(c) sentences in light of other mandatory minimums)
United States v. MilLet, 510 F.3d 668 (7th Cir. 2007) (factors for entrapment predisposition)
United States v. Blassingame, 197 F.3d 271 (7th Cir. 1999) (predisposition and entrapment framework)
United States v. Swiatek, 819 F.2d 721 (7th Cir. 1987) (admissibility of prior bad acts for predisposition)
United States v. Smith, 454 F.3d 707 (7th Cir. 2006) (impeachment by prior convictions; discretion)
United States v. Souffront, 338 F.3d 809 (7th Cir. 2003) (hearsay and evidentiary rulings; impeachment)
United States v. Li, 55 F.3d 325 (7th Cir. 1995) (completeness/statement context)
United States v. Garcia, 897 F.2d 1413 (7th Cir. 1990) (Rule 804(b)(3) penal-interest corroboration)
United States v. Marin, 669 F.2d 73 (2d Cir. 1982) (completeness doctrine limits)
United States v. Walker, 652 F.2d 708 (7th Cir. 1981) (Sixth Amendment considerations in cross-examination)