United States v. Benitez-Lopez

CourtCourt of Appeals for the Tenth Circuit
DecidedNovember 10, 2020
Docket19-1439
StatusUnpublished

This text of United States v. Benitez-Lopez (United States v. Benitez-Lopez) is published on Counsel Stack Legal Research, covering Court of Appeals for the Tenth 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. Benitez-Lopez, (10th Cir. 2020).

Opinion

UNITED STATES COURT OF APPEALS FILED United States Court of Appeals Tenth Circuit FOR THE TENTH CIRCUIT _________________________________ November 10, 2020 UNITED STATES OF AMERICA, Christopher M. Wolpert Clerk of Court Plaintiff - Appellee, No. 19-1439 v. (D.C. No. 1:18-CR-00328-PAB-6) (D. Colo.) MICHAEL BENITEZ-LOPEZ, a/k/a Mikey, a/k/a Money Mike,

Defendant - Appellant. _________________________________

ORDER AND JUDGMENT * _________________________________

Before HOLMES, BACHARACH, and MORITZ, Circuit Judges. _________________________________

Mr. Michael Benitez-Lopez was charged with federal drug offenses. 1

To support the charges, the government offered into evidence a letter that

* The parties have not requested oral argument, and it would not materially help us in deciding the appeal. We have thus decided the appeal based on the briefs and the record on appeal. See Fed. R. App. P. 34(a)(2)(C); 10th Cir. R. 34.1(G).

Our order and judgment does not constitute binding precedent except under the doctrines of law of the case, res judicata, and collateral estoppel. But the order and judgment may be cited for its persuasive value under Fed. R. App. P. 32.1(a) and 10th Cir. R. 32.1(A). 1. The charges involved

 possession with intent to distribute a mixture of a Schedule II controlled substance, Mr. Benitez-Lopez had written from jail. In the letter, he had told his

girlfriend that his mother might be subpoenaed, adding: “But tell here [sic]

if they Do to Just say she don’t know shit she plays the 5 t h , Because I

guess she was in some calls of mines [sic].” The letter also stated, “tell my

mom asap what I siad [sic] K!”

Mr. Benitez-Lopez objected on the ground of unfair prejudice, and

the court overruled the objection. The jury ultimately found guilt on all of

the charges; and at sentencing, the court relied on the letter to apply a two-

level enhancement for attempted obstruction of justice. See USSG § 3C1.1.

On appeal, Mr. Benitez-Lopez argues that the district court erred in

allowing introduction of the letter and using it to apply the sentencing

enhancement. We affirm. 2

 conspiracy to distribute or possess with intent to distribute a mixture containing cocaine, and

 use of a communication facility with intent to distribute a Schedule II controlled substance and aiding and abetting this offense. 2. Mr. Benitez-Lopez filed the notice of appeal between the sentencing and final judgment. Though the notice was premature, it ripened upon entry of the final judgment. See United States v. Gachot, 512 F.3d 1252, 1253 n.2 (10th Cir. 2008) (concluding that a notice of appeal ripened upon entry of a final judgment even though the notice had preceded the final judgment).

2 I. The district court did not abuse its discretion in allowing introduction of the letter into evidence.

On appeal, Mr. Benitez-Lopez argues that introduction of the letter

created unfair prejudice 3 by showing that he had been incarcerated on the

current charge. The government argues that Mr. Benitez-Lopez failed to

preserve this argument. For the sake of argument, we may assume that the

argument was preserved. Even with preservation, however, the argument

would fail.

If the argument had been preserved, we would apply the abuse-of-

discretion standard. United States v. Cherry, 433 F.3d 698, 700 (10th Cir.

2005). This discretion is particularly broad when the district court balances

the probative value of evidence against the risk of unfair prejudice. Id. at

702. In determining whether the court abused its broad discretion, we

consider “(1) whether the evidence was relevant, (2) whether it had the

potential to unfairly prejudice the defendant, and (3) whether its probative

value was substantially outweighed by the danger of unfair prejudice.”

United States v. Watson, 766 F.3d 1219, 1241 (10th Cir. 2014) (quoting

United States v. MacKay, 715 F.3d 807, 839 (10th Cir. 2013)). When

3. In a subheading and a few sentences, Mr. Benitez-Lopez also suggests that introduction of the letter denied him a fair trial. Reference to a “fair trial” could suggest a denial of due process. But Mr. Benitez-Lopez did not object based on this ground, so he forfeited a distinct challenge involving a denial of due process. United States v. McGlothin, 705 F.3d 1254, 1256–57 (10th Cir. 2013). 3 balancing probative value and unfair prejudice, we “should ‘give the

evidence its maximum reasonable probative force and its minimum

reasonable prejudicial value.’” Deters v. Equifax Credit Info. Servs., Inc.,

202 F.3d 1262, 1274 (10th Cir. 2000) (quoting SEC v. Peters, 978 F.2d

1162, 1171 (10th Cir. 1992)).

Mr. Benitez-Lopez challenges our application of the balancing test,

arguing that

 the letter lacked relevance and

 the discussion of the letter during the deputy sheriff’s testimony signaled to the jury that Mr. Benitez-Lopez “was not only in custody, but in custody for this particular offense.”

Appellant’s Opening Br. at 21. We reject these arguments.

The district court could plausibly interpret the letter as an instruction

to Mr. Benitez-Lopez’s mother to lie by saying that she didn’t know

anything (even though she had participated in some of the pertinent phone

calls). Given the plausibility of this interpretation, the district court could

reasonably regard the letter as evidence of Mr. Benitez-Lopez’s

consciousness of guilt.

The court could also reasonably discount the possibility that the

letter might suggest why Mr. Benitez-Lopez was in jail. Though Mr.

Benitez-Lopez had written the letter from jail, neither the letter nor the

4 deputy sheriff said anything about the nature of the charge or the reason

for his incarceration. 4

Of course, even without specifics, the letter implied that Mr.

Benitez-Lopez was incarcerated. Though the fact of his incarceration was

prejudicial, the court could reasonably regard the prejudice as fair because

it omitted any additional damaging details. See United States v. Silva, 889

F.3d 704, 715 (10th Cir. 2018), cert. denied, 139 S. Ct. 1319, 203 L. Ed.

2d 572 (2019) (noting that the appellant’s proposed redactions were not

necessary to avoid unfair prejudice because the evidence was limited to the

fact of conviction and did not include other details). And even if some

parts might have been prejudicial, the district court offered to redact

prejudicial parts of the letter.

Given the district court’s discretion, we conclude that the court did

not err in balancing the probative value against the danger of unfair

prejudice.

4. In the letter, Mr. Benitez-Lopez didn’t say that he was incarcerated. But he did

 say that he needed to “see you guys soon” and didn’t want to be “in here for a long time” and

 ask his girlfriend how things were “out there.”

5 II.

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Related

Deters v. Equifax Credit Information Services, Inc.
202 F.3d 1262 (Tenth Circuit, 2000)
United States v. Hawthorne
316 F.3d 1140 (Tenth Circuit, 2003)
United States v. Cherry
433 F.3d 698 (Tenth Circuit, 2005)
United States v. Gachot
512 F.3d 1252 (Tenth Circuit, 2008)
United States v. Stanley Douglas Powell
973 F.2d 885 (Tenth Circuit, 1992)
Securities and Exchange Commission v. Don S. Peters
978 F.2d 1162 (Tenth Circuit, 1992)
United States v. Fleming
667 F.3d 1098 (Tenth Circuit, 2011)
United States v. McGlothin
705 F.3d 1254 (Tenth Circuit, 2013)
United States v. MacKay
715 F.3d 807 (Tenth Circuit, 2013)
United States v. Watson
766 F.3d 1219 (Tenth Circuit, 2014)
United States v. Silva
889 F.3d 704 (Tenth Circuit, 2018)

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United States v. Benitez-Lopez, Counsel Stack Legal Research, https://law.counselstack.com/opinion/united-states-v-benitez-lopez-ca10-2020.