Sunday, December 22, 2013

United States v. Brown case brief (Evidence)

United States v. Brown case brief summary
299 F.3d 1252 (11th Cir. 1999)

CASE SYNOPSIS
Defendant appealed from the judgment of the United States District Court for the Southern District of Florida, convicting her for importation of 500 grams or more of a mixture and substance containing a detectable amount of cocaine, and possession with intent to distribute 500 grams or more of a mixture and substance containing a detectable amount of cocaine.

CASE FACTS
Defendant challenged the prosecution's use of its peremptory strikes in jury selection, evidentiary rulings by the district court, and the district court's denial of a motion to withdraw made by her retained counsel.

DISCUSSION

  • The court initially held that the district court did not clearly err in finding that the race-neutral reasons offered by the prosecution for its jury selection strikes were credible, and that defendant failed to offer evidence to establish any pretext by the prosecution. 
  • The court then held that the testimony of the prosecution's drug valuation expert was properly admitted by the district court and did not violate defendant's confrontation rights because he relied on data of a type reasonably relied upon by drug valuation experts, and his testimony was subject to cross-examination by defendant, and that the prosecution's drug price list was properly excluded by the district court. 
  • The court finally held that it had no jurisdiction to review the denial of defendant's withdrawal motion.

CONCLUSION
The convictions were affirmed.

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