United States v. Alexander Juarez-Sanchez

CourtCourt of Appeals for the Fourth Circuit
DecidedMay 21, 2024
Docket22-4477
StatusUnpublished

This text of United States v. Alexander Juarez-Sanchez (United States v. Alexander Juarez-Sanchez) is published on Counsel Stack Legal Research, covering Court of Appeals for the Fourth Circuit primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
United States v. Alexander Juarez-Sanchez, (4th Cir. 2024).

Opinion

USCA4 Appeal: 22-4477 Doc: 42 Filed: 05/21/2024 Pg: 1 of 5

UNPUBLISHED

UNITED STATES COURT OF APPEALS FOR THE FOURTH CIRCUIT

No. 22-4477

UNITED STATES OF AMERICA,

Plaintiff - Appellee,

v.

ALEXANDER JUAREZ-SANCHEZ,

Defendant - Appellant.

Appeal from the United States District Court for the District of Maryland, at Baltimore. Julie R. Rubin, District Judge. (1:21-cr-00174-JRR-1)

Submitted: April 29, 2024 Decided: May 21, 2024

Before GREGORY and RUSHING, Circuit Judges, and KEENAN, Senior Circuit Judge.

Affirmed by unpublished per curiam opinion.

ON BRIEF: Alfred Guillaume, III, LAW OFFICES OF ALFRED GUILLAUME III, Greenbelt, Maryland, for Appellant. Erek L. Barron, United States Attorney, Baltimore, Maryland, Adam K. Ake, Assistant United States Attorney, OFFICE OF THE UNITED STATES ATTORNEY, Greenbelt, Maryland, for Appellee.

Unpublished opinions are not binding precedent in this circuit. USCA4 Appeal: 22-4477 Doc: 42 Filed: 05/21/2024 Pg: 2 of 5

PER CURIAM:

A jury convicted Alexander Juarez-Sanchez of conspiracy to distribute controlled

substances, in violation of 21 U.S.C. § 846; possession with intent to distribute controlled

substances, in violation of 21 U.S.C. § 841; and reentry after deportation, in violation of 8

U.S.C. § 1326(a). On appeal, Juarez-Sanchez challenges one of the district court’s pretrial

suppression rulings, the court’s decision to qualify one of the Government’s witnesses as

an expert, and a comment made by the Government during its closing argument. We

affirm.

In his first claim, Juarez-Sanchez argues that two search warrants issued in this case

were not supported by probable cause. Below, the district court rejected this argument and,

in the alternative, held that the good faith exception to the exclusionary rule applied. See

United States v. Brunson, 968 F.3d 325, 334 (4th Cir. 2020) (“[E]vidence ‘seized in

reasonable, good-faith reliance on a search warrant that is subsequently held to be

defective’ is not subject to suppression, despite the existence of a constitutional violation.”

(quoting United States v. Leon, 468 U.S. 897, 905 (1984)). On appeal, Juarez-Sanchez

neglects to challenge the court’s application of the good faith exception; consequently, he

has waived appellate review of this issue, United States v. Ebert, 61 F.4th 394, 402 (4th

Cir.), cert. denied, 144 S. Ct. 149 (2023), so we need not consider the validity of the

warrants.

Next, Juarez-Sanchez asserts that the district court abused its discretion when

allowing one of the Government’s fact witnesses to provide expert testimony. Under Fed.

R. Evid. 702, expert testimony is permitted if it “is (1) helpful to the jury in understanding

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the evidence or determining a fact at issue, (2) based on sufficient facts or data, (3) the

product of reliable principles and methods, and (4) the product of a reliable application of

those principles and methods to the facts of the case.” Sardis v. Overhead Door Corp., 10

F.4th 268, 281 (4th Cir. 2021) (cleaned up). “We review a district court’s decision to

qualify an expert witness, as well as the admission of such testimony, for abuse of

discretion.” United States v. Garcia, 752 F.3d 382, 390 (4th Cir. 2014).

The Government’s first witness, a Maryland State Police officer, testified as a fact

witness about conducting a traffic stop that led to Juarez-Sanchez’s arrest and prosecution.

Later, the Government recalled the officer to provide expert testimony on the subject of

illicit drug trafficking. After extensive voir dire, the district court found that the officer’s

training and experience were sufficient to qualify him as an expert. Based on our review

of the record, we discern no abuse of discretion.

In a related argument, Juarez-Sanchez takes issue with the district court’s cautionary

instruction, which admonished the jury “to differentiate [the officer’s] testimony about his

personal experience with the traffic stop and his expert opinion . . . in the field of illicit

drug trafficking.” (J.A. * 675). Because Juarez-Sanchez did not object at trial, we review

only for plain error. United States v. Baptiste, 596 F.3d 214, 224 (4th Cir. 2010)

“[D]ual-role testimony—like all testimony—requires a determination of whether

‘its probative value is substantially outweighed’ by the risk of unfair prejudice or jury

confusion.” United States v. Smith, 919 F.3d 825, 837 (4th Cir. 2019) (quoting Fed. R.

* Citations to “J.A.” refer to the joint appendix filed in this appeal.

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Evid. 403)). “To maintain this Rule 403 balance, district courts must be vigilant to avoid

the danger of confusing the jury when a [police officer] testifies as an expert” and as a fact

witness. Id. “[E]xamples of safeguards the district court may employ” include “requiring

the witness to testify at different times, in each capacity[,]” and “giving a cautionary

instruction to the jury regarding the basis of the testimony.” Id. (internal quotation marks

omitted).

Here, the officer testified at separate times, and the district court provided an

appropriate cautionary instruction. Furthermore, during the expert portion of his

testimony, the officer made no mention of Juarez-Sanchez or the traffic stop. For these

reasons, we discern no plain error in the court’s handling of this matter.

Finally, Juarez-Sanchez insists that a comment made during the Government’s

closing argument deprived him of a fair trial. “[T]his Court reviews a claim of

prosecutorial misconduct to determine whether the conduct so infected the trial with

unfairness as to make the resulting conviction a denial of due process.” United States v.

Whyte, 918 F.3d 339, 352 (4th Cir. 2019) (internal quotation marks omitted). “In

determining whether a defendant’s due process rights were violated by a prosecutor’s

closing argument, we consider (1) whether the remarks were, in fact, improper, and, (2) if

so, whether the improper remarks so prejudiced the defendant’s substantial rights that the

defendant was denied a fair trial.” United States v. Saint Louis, 889 F.3d 145, 156 (4th Cir.

2018) (internal quotation marks omitted).

Following the traffic stop, law enforcement seized from the vehicle multiple

kilograms of fentanyl and heroin, a substantial sum of cash, and two cell phones that

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allegedly belonged to Juarez-Sanchez, who had been riding as a passenger. Based on

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Related

United States v. Leon
468 U.S. 897 (Supreme Court, 1984)
United States v. Baptiste
596 F.3d 214 (Fourth Circuit, 2010)
United States v. Danilo Garcia
752 F.3d 382 (Fourth Circuit, 2014)
United States v. Monclaire Saint Louis
889 F.3d 145 (Fourth Circuit, 2018)
United States v. William Whyte
918 F.3d 339 (Fourth Circuit, 2019)
United States v. Michael Smith
919 F.3d 825 (Fourth Circuit, 2019)
United States v. Joey Brunson
968 F.3d 325 (Fourth Circuit, 2020)
Andrea Sardis v. Overhead Door Corporation
10 F. 4th 268 (Fourth Circuit, 2021)
United States v. William Ebert
61 F.4th 394 (Fourth Circuit, 2023)

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