United States v. Garcia

CourtCourt of Appeals for the Second Circuit
DecidedMay 23, 2025
Docket24-923 (L)
StatusUnpublished

This text of United States v. Garcia (United States v. Garcia) is published on Counsel Stack Legal Research, covering Court of Appeals for the Second 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. Garcia, (2d Cir. 2025).

Opinion

24-923 (L) United States v. Garcia

UNITED STATES COURT OF APPEALS FOR THE SECOND CIRCUIT

SUMMARY ORDER

RULINGS BY SUMMARY ORDER DO NOT HAVE PRECEDENTIAL EFFECT. CITATION TO A SUMMARY ORDER FILED ON OR AFTER JANUARY 1, 2007, IS PERMITTED AND IS GOVERNED BY FEDERAL RULE OF APPELLATE PROCEDURE 32.1 AND THIS COURT’S LOCAL RULE 32.1.1. WHEN CITING A SUMMARY ORDER IN A DOCUMENT FILED WITH THIS COURT, A PARTY MUST CITE EITHER THE FEDERAL APPENDIX OR AN ELECTRONIC DATABASE (WITH THE NOTATION “SUMMARY ORDER”). A PARTY CITING TO A SUMMARY ORDER MUST SERVE A COPY OF IT ON ANY PARTY NOT REPRESENTED BY COUNSEL.

At a stated term of the United States Court of Appeals for the Second Circuit, held at the Thurgood Marshall United States Courthouse, 40 Foley Square, in the City of New York, on the 23rd day of May, two thousand twenty-five.

PRESENT: ROBERT D. SACK, RICHARD C. WESLEY, BETH ROBINSON, Circuit Judges. _________________________________________

UNITED STATES OF AMERICA,

Appellee,

v. Nos. 24-923 (Lead), 24-1468 (Con) JONATHAN GARCIA, CHRISTOPHER NELSON,

Defendants-Appellants,

MARK WOODS, CARMELO VELEZ, CHRISTOPHER RODRIGUEZ, ANGEL LOPEZ, CHRISTOPHER LUM, ALBERTO BORGES, DEESHUNTEE STEVENS, DIEGO MATEO, LUIS SEPULVEDA, EMMANUEL BONAFE, JOSIAH VELAZQUEZ, JUAN HERNANDEZ, JESUS HERNANDEZ, HEINNER SOLIS, EZEQUIEL OSPINA, RAIMUNDO NIEVES, HECTOR BONAPARTE, MICHAEL GONZALEZ, JUPANKY PIMENTEL, WILLIAM GONZALEZ, RICARDO RICUARTE, RAUL CUELLO, PAUL CUELLO,

Defendants. *

_________________________________________

FOR APPELLEE: PATRICK R. MORONEY, Assistant United States Attorney (Adam S. Hobson, David J. Robles, Stephanie Simon, Assistant United States Attorneys, on the brief), for Danielle R. Sassoon, United States Attorney for the Southern District of New York, New York, NY.

FOR DEFENDANT-APPELLANT GARCIA: JOHN S. WALLENSTEIN, Law Office of John S. Wallenstein, Garden City, NY.

FOR DEFENDANT-APPELLANT NELSON: STEPHANIE M. CARVLIN, Law Office of Stephanie Carvlin, New York, NY.

* The Clerk’s office is respectfully directed to amend the caption as reflected above.

2 Appeal from a judgment of the United States District Court for the Southern

District of New York (Caproni, Judge).

UPON DUE CONSIDERATION WHEREOF, IT IS HEREBY ORDERED,

ADJUDGED, AND DECREED that the judgments entered on April 5, 2024, and

May 15, 2024, are AFFIRMED.

Defendant-Appellant Jonathan Garcia appeals after a jury trial from a

judgment of conviction of racketeering conspiracy, in violation of 18 U.S.C.

§§ 1962(d) and 1963; murder in aid of racketeering, in violation of 18 U.S.C.

§ 1959(a)(1); narcotics conspiracy, in violation of 21 U.S.C. §§ 846 and 841(b)(1)(A);

and brandishing a firearm in furtherance of a drug trafficking crime, in violation

of 18 U.S.C. § 924(c)(1)(A). Defendant-Appellant Christopher Nelson appeals

from a judgment revoking his supervised release and sentencing him for violating

the conditions of his supervised release. Because these appeals involve distinct

challenges to unrelated judgments, we address each separately. We assume the

parties’ familiarity with the underlying facts, procedural history, and arguments

on appeal, to which we refer only as necessary to explain our decision.

3 I. Garcia

We consider in turn Garcia’s arguments that the district court improperly

admitted hearsay testimony, that the evidence was insufficient to support his

murder in aid of racketeering conviction, and that venue was improper.

A. Hearsay

Garcia argues that the district court impermissibly admitted as

coconspirator statements out-of-court statements about the murder by declarants

who were not part of a conspiracy to commit the charged murder. See Fed. R. Evid.

801(d)(2). Garcia does not identify the specific statements made by the five

cooperating former fellow Latin Kings members he claims were admitted in error.

“We review a district court’s evidentiary rulings under a deferential abuse

of discretion standard.” United States v. Kandic, 134 F.4th 92, 99 (2d Cir. 2025). 1 A

statement “made by the party’s coconspirator during and in furtherance of the

conspiracy” is not a hearsay statement. Fed. R. Evid. 801(d)(2)(E). “To admit a

statement under the coconspirator exception to the hearsay definition, a district

court must find two factors by a preponderance of the evidence: first, that a

1 In quotations from caselaw and the parties’ briefing, this summary order omits all internal quotation marks, footnotes, and citations, and accepts all alterations, unless otherwise noted.

4 conspiracy existed that included the defendant and the declarant; and second, that

the statement was made during the course of and in furtherance of that

conspiracy.” United States v. Gigante, 166 F.3d 75, 82 (2d Cir. 1999).

We generally review Garcia’s challenge for plain error because he did not

contemporaneously object to the vast majority of the contested statements at trial,

even though the district court deferred to trial definitive rulings on the

government’s pretrial motions. United States v. Simels, 654 F.3d 161, 168 (2d Cir.

2011) (“[I]f a defendant fails to make a sufficient objection in the district court, the

evidentiary claim is reviewed . . . under the plain error standard.”); cf. United States

v. Yu-Leung, 51 F.3d 1116, 1121 (2d Cir. 1995) (holding that a pretrial motion

seeking to exclude evidence may preserve an objection where, among other things,

it “is ruled upon without equivocation by the trial judge”). Plain error is shown

when “(1) there is an error; (2) the error is clear or obvious, rather than subject to

reasonable dispute; (3) the error affected the appellant’s substantial rights, which

in the ordinary case means it affected the outcome of the district court proceedings;

and (4) the error seriously affects the fairness, integrity or public reputation of

judicial proceedings.” United States v. Marcus, 560 U.S. 258, 262 (2010).

5 To the extent that Garcia argues all after-the-fact, out-of-court statements

about the murder made by fellow Latin Kings members who were not themselves

involved in the murder are necessarily inadmissible, we reject his argument as

overbroad. “[S]tatements relating past events meet the in-furtherance test if they

serve some current purpose in the conspiracy, such as to promote cohesiveness.”

United States v. Thai, 29 F.3d 785, 813 (2d Cir. 1994). And Garcia has failed to

identify for our review any specific statements he contends the district court

admitted in error.

Moreover, even if Garcia had identified specific statements that were

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United States v. Garcia, Counsel Stack Legal Research, https://law.counselstack.com/opinion/united-states-v-garcia-ca2-2025.