United States v. Trinidad-Acosta, 2014 U.S. App. LEXIS 22962

Conspiracy to distribute crack cocaine operated out of Bangor, Maine, led from New York; drugs shipped by bus and stored at 100B Ohio Street.
Trinidad, known as Fish/Peje, lived at and helped run the Ohio Street stash location; deposited drug proceeds into Cabrera’s account.
Cogswell, a daily crack cocaine user, acted as a dealer and lived at 100B Ohio Street; he moved drugs and provided cash deposits to Cabrera’s account.
Jennifer Holmes purchased crack and firearms for conspirators, including Trinidad, and was compensated with crack cocaine.
Law enforcement raided the Ohio Street apartment in November 2011; many co-conspirators cooperated, but Trinidad and Cogswell did not; both were convicted after a five-day trial.
Trinidad was sentenced to 240 months (180 on conspiracy count and 60 consecutive on firearm count); Cogswell received 180 months; both sentences below the advisory Guidelines range.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Mistrial denial based on Holmes’s remark	Trinidad argues the remark prejudiced innocence presumption	Trinidad contends the remark was highly prejudicial and warranted a mistrial	No reversible error; no manifest abuse of discretion; strong independent evidence supported guilt
Sentence reasonableness for Trinidad	Sentence below advisory range was unreasonable given his role	Court afforded careful §3553(a) consideration and reasoned distinction from co-conspirators	Affirmed; district court’s rationale and below-range sentence were defensible
Sufficiency of evidence against Cogswell	Evidence shows Cogswell as a user who sold on the side, not a conspirator	Five Bangor witnesses plus other corroboration show ongoing conspiracy participation	Sustained; a rational jury could find he knowingly joined the conspiracy beyond reasonable doubt
Closing arguments misstatements and plain-error review (Cogswell)	Misstatements potentially deprived defendant of defense validity	Objections timely; strong evidence mitigates prejudice; instructions mitigated impact	Harmless error; no reversal; statements unlikely affected outcome
Obstruction and firearm enhancements (Cogswell)	Enhancements properly applied for obstruction and weapon in furtherance of conspiracy	Challenged scope and timing of obstruction and firearm applicability	Upheld; enhancements supported by record and foreseeability of firearm and threat

Estelle v. Williams, 425 U.S. 501 (1976) (prison clothing violates presumption of innocence when worn throughout trial)
Gall v. United States, 552 U.S. 38 (2007) (reasonableness involves procedurally sound and substantively reasonable sentences)
Díaz, 494 F.3d 221 (1st Cir. 2007) (taint and mistrial rulings evaluated under totality of circumstances)
De Jesús Mateo, 373 F.3d 70 (1st Cir. 2004) (brief, isolated pretrial incarceration references are generally permissible)
Deandrade, 600 F.3d 115 (2d Cir. 2010) (limits on improper witness identification remarks in cross-examination context)
Searcy, 316 F.3d 550 (5th Cir. 2002) (indirect threats may constitute obstruction where threat likely conveyed to witness)
Sotomayor-Vázquez, 249 F.3d 1 (1st Cir. 2001) (use of closing arguments and preserved objections in evaluating error)