United States v. Winfred Trammel
671 F. App'x 239
| 5th Cir. | 2016Background
- Trammel was convicted by a jury of conspiracy to possess with intent to distribute 50 grams or more of a methamphetamine-containing substance.
- At trial the Government presented evidence that Trammel was a repeat purchaser of relatively large quantities and was sometimes fronted drugs by alleged co-conspirators.
- Trammel argued he was only a buyer-seller and that the evidence did not prove participation in a conspiracy.
- He also contended the Government proved a different conspiracy than charged and that text-message evidence admitted at trial was inadmissible hearsay and violated the Confrontation Clause.
- At sentencing the court applied a two-level obstruction-of-justice enhancement under U.S.S.G. § 3C1.1 based on the court’s finding that Trammel willfully gave false testimony at a suppression hearing about Miranda warnings.
- The Fifth Circuit affirmed both the conviction and the sentence.
Issues
| Issue | Plaintiff's Argument (Trammel) | Defendant's Argument (Government) | Held |
|---|---|---|---|
| Sufficiency: whether evidence shown supports conspiracy conviction | He was a mere buyer-seller; insufficient proof of conspiracy | Evidence of repeat large purchases and being fronted drugs shows conspiracy participation | Affirmed — rational juror could find conspiracy |
| Variance: proof of a different conspiracy than indicted | Trial proved a different conspiracy (time, participants, scope, location) | Evidence matched indictment on time, participants, scope, and location | Affirmed — no fatal variance |
| Admission of text messages: hearsay and Confrontation Clause challenge | Messages were hearsay and testimonial; admission violated confrontation rights because sender didn’t testify | Messages fall under co-conspirator statements in furtherance exception and are non-testimonial | Affirmed — admissible under Fed. R. Evid. 801(d)(2)(E) and not testimonial |
| Sentencing: § 3C1.1 obstruction enhancement for false testimony | Enhancement was improper; sentencing unreasonable | District court found willful false statements at suppression hearing; enhancement supported by record | Affirmed — factual finding not clearly erroneous; enhancement proper |
Key Cases Cited
- United States v. Maseratti, 1 F.3d 330 (5th Cir.) (repeat large purchases can indicate conspiracy)
- United States v. Posada-Rios, 158 F.3d 832 (5th Cir. 1998) (fronting drugs shows mutual trust and interdependence among conspirators)
- United States v. Thomas, 12 F.3d 1350 (5th Cir.) (variance and sufficiency principles)
- United States v. Jackson, 636 F.3d 687 (5th Cir. 2011) (standard of review for evidentiary rulings)
- United States v. Snyder, 930 F.2d 1090 (5th Cir.) (co-conspirator statements exception application)
- United States v. Alaniz, 726 F.3d 586 (5th Cir.) (co-conspirator statements are non-testimonial for Confrontation Clause)
- Gall v. United States, 552 U.S. 38 (2007) (procedural review and substantive-reasonableness framework for sentences)
- United States v. Delgado-Martinez, 564 F.3d 750 (5th Cir.) (sentencing review standards)
- United States v. Cisneros-Gutierrez, 517 F.3d 751 (5th Cir.) (clear-error standard for factual sentencing findings)