Case Brief: United States v. Glenn - Admissibility and Sufficiency of Evidence in Drug Conspiracy Convictions

Case Brief: United States v. Glenn, 667 F.2d 1269 (9th Cir. 1982)

Court

United States Court of Appeals for the Ninth Circuit

Facts

Roy Glenn was convicted of conspiracy to distribute and possess with intent to distribute heroin. Glenn was implicated in a drug trafficking operation that was uncovered through a combination of surveillance, informant testimony, and intercepted communications. Glenn challenged his conviction on several grounds, including the admissibility of evidence and the sufficiency of the evidence supporting his conviction.

Issue

1. Was the evidence obtained through surveillance and informant testimony admissible?
2. Was the evidence sufficient to support Glenn's conviction for conspiracy to distribute and possess with intent to distribute heroin?

Holding

1. Yes. The evidence obtained through surveillance and informant testimony was admissible.
2. Yes. The evidence was sufficient to support Glenn's conviction.

Reasoning

The court reviewed the admissibility of the evidence and found no error in the trial court's rulings. The surveillance was conducted legally, and the informant's testimony was corroborated by other evidence, making it reliable and admissible. The court also found that the evidence presented at trial, including intercepted communications and surveillance footage, was sufficient to establish Glenn's participation in the conspiracy beyond a reasonable doubt.

Rule of Law

• Admissibility of Evidence: Surveillance and informant testimony are admissible if conducted and obtained legally and if corroborated by other reliable evidence.
• Sufficiency of Evidence: A conviction for conspiracy can be upheld if the evidence, viewed in the light most favorable to the prosecution, supports the jury's finding of guilt beyond a reasonable doubt.

Important Points

• Legality of Surveillance: The court emphasized that surveillance must comply with legal standards to be admissible.
• Reliability of Informant Testimony: Informant testimony is admissible if corroborated by other evidence.
• Conspiracy Conviction: To uphold a conspiracy conviction, the evidence must show that the defendant knowingly participated in the conspiracy with intent to further its illegal objectives.

Cited Cases

• United States v. Turner, 528 F.2d 143 (9th Cir. 1975): Discussed the admissibility of surveillance evidence in drug trafficking cases.
• United States v. Spanos, 462 F.2d 1012 (9th Cir. 1972): Addressed the use of informant testimony and the need for corroboration.
• United States v. Dunn, 564 F.2d 348 (9th Cir. 1977): Provided standards for evaluating the sufficiency of evidence in conspiracy cases.

Similar Cases

• United States v. Brown, 912 F.2d 1040 (9th Cir. 1990): Addressed the sufficiency of evidence in drug conspiracy convictions.
• United States v. Cruz, 783 F.2d 1470 (9th Cir. 1986): Discussed the admissibility of wiretap evidence in drug trafficking cases.
• United States v. Hernandez, 876 F.2d 774 (9th Cir. 1989): Explored the role of informant testimony in securing drug conspiracy convictions.

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