United States v. Leonardo Muro

CourtCourt of Appeals for the Fourth Circuit
DecidedAugust 19, 2019
Docket19-4021
StatusUnpublished

This text of United States v. Leonardo Muro (United States v. Leonardo Muro) 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. Leonardo Muro, (4th Cir. 2019).

Opinion

UNPUBLISHED

UNITED STATES COURT OF APPEALS FOR THE FOURTH CIRCUIT

No. 19-4021

UNITED STATES OF AMERICA,

Plaintiff - Appellee,

v.

LEONARDO CHAVARRIA MURO,

Defendant - Appellant.

Appeal from the United States District Court for the Western District of North Carolina, at Asheville. Martin K. Reidinger, District Judge. (1:17-cr-00124-MR-WCM-1)

Submitted: July 31, 2019 Decided: August 19, 2019

Before NIEMEYER and RICHARDSON, Circuit Judges, and TRAXLER, Senior Circuit Judge.

Affirmed by unpublished per curiam opinion.

Anthony Martinez, Federal Public Defender, Ann L. Hester, Assistant Federal Public Defender, FEDERAL DEFENDERS OF WESTERN NORTH CAROLINA, INC., Charlotte, North Carolina, for Appellant. R. Andrew Murray, United States Attorney, Amy E. Ray, Assistant United States Attorney, OFFICE OF THE UNITED STATES ATTORNEY, Asheville, North Carolina, for Appellee.

Unpublished opinions are not binding precedent in this circuit. PER CURIAM:

Leonardo Chavarria Muro appeals his conviction for distribution and possession

with intent to distribute at least 50 grams of methamphetamine, in violation of 21 U.S.C.

§§ 841(a)(1), (b)(1)(A)(viii) (2012). Muro argues on appeal that the district court abused

its discretion by accepting into evidence a transcription and translation prepared by a

witness who was not proffered as an expert under Rule 702 of the Federal Rules of

Evidence. We affirm the district court’s judgment.

Assuming without deciding that Muro’s objection at trial preserved the issue he

seeks to raise on appeal, we review the district court’s evidentiary ruling for an abuse of

discretion and “will only overturn a ruling that is arbitrary and irrational.” United States

v. Farrell, 921 F.3d 116, 143 (4th Cir. 2019) (alteration and internal quotation marks

omitted). “A court has abused its discretion if its decision is guided by erroneous legal

principles or rests upon a clearly erroneous factual finding.” United States v. Johnson, 617

F.3d 286, 292 (4th Cir. 2010) (internal quotation marks omitted). We will not vacate a

conviction under this standard, however, if an error was harmless. United States v.

Sutherland, 921 F.3d 421, 429 (4th Cir. 2019). “In order to find a district court’s error

harmless, we need only be able to say with fair assurance, after pondering all that happened

without stripping the erroneous action from the whole, that the judgment was not

substantially swayed by the error.” Johnson, 617 F.3d at 292 (internal quotation marks

omitted).

Rule 701 of the Federal Rules of Evidence governs lay opinion evidence and

authorizes a witness “not testifying as an expert” to present opinion evidence that is:

2 “(a) rationally based on the witness’s perception; (b) helpful to clearly understanding the

witness’s testimony or to determining a fact in issue; and (c) not based on scientific,

technical, or other specialized knowledge within the scope of Rule 702.” Fed. R. Evid.

701. In contrast, Rule 702 of the Federal Rules of Evidence provides that “[a] witness who

is qualified as an expert by knowledge, skill, experience, training, or education may testify

in the form of an opinion” if (1) the expert’s specialized knowledge will help the jury to

understand the evidence or determine a fact in issue; (2) the testimony is based on sufficient

facts or data; (3) the testimony is the product of reliable principles and methods; which

(4) the expert reliably applied to the facts of the case. Fed. R. Evid. 702.

“[T]he line between lay opinion testimony under Rule 701 and expert testimony

under Rule 702 is a fine one, [and] the guiding principle in distinguishing lay from expert

opinion is that lay testimony must be based on personal knowledge.” Farrell, 921 F.3d at

143 (internal quotation marks omitted). Courts must also consider “whether the proposed

testimony relies on some specialized knowledge or skill or education that is not in the

possession of the jurors.” Id. at 143-44 (internal quotation marks omitted).

Thus, in undertaking its gatekeeper role to ensure that evidence is reliable under

Rule 702, a district court “must decide whether the expert has ‘sufficient specialized

knowledge to assist the jurors in deciding the particular issues in the case.’” Belk, Inc. v.

Meyer Corp., U.S., 679 F.3d 146, 162 (4th Cir. 2012) (quoting Kumho Tire Co. v.

Carmichael, 526 U.S. 137, 156, (1999)). In making this decision, the court should

“consider the proposed expert’s full range of experience and training.” United States v.

Pansier, 576 F.3d 726, 737 (7th Cir. 2009). “[A] witness’ qualifications to render an expert

3 opinion are . . . liberally judged by Rule 702.” Kopf v. Skyrm, 993 F.2d 374, 377 (4th Cir.

1993). If the district court erroneously admits opinion testimony under Rule 701, the error

is harmless if the witness could have been offered as an expert under Rule 702 in the first

instance. See United States v. Perkins, 470 F.3d 150, 156-57 (4th Cir. 2006) (applying

plain error review, no error where witnesses could have been offered as experts based on

their experience and training); see also United States v. Figueroa-Lopez, 125 F.3d 1241,

1246-47 (9th Cir. 1997) (holding that, although it was error for district court to admit

opinion testimony under Rule 701, error was harmless because witnesses could have been

qualified as experts under Rule 702).

We find that any error in the admission of the witness’ opinion here was harmless.

Assuming that the government should have proffered the witness as an expert, we find that

she would have qualified as an expert under Rule 702 in the first instance. Although the

witness is not a federally certified interpreter, the lack of formal certification by a

professional organization—although relevant to her expertise—is not dispositive; Rule 702

“does not require any particular imprimatur.” United States v. Gutierrez, 757 F.3d 785,

788 (8th Cir. 2014); see United States v. Barker, 553 F.2d 1013, 1024 (6th Cir. 1977) (“An

expert need not have certificates of training, nor memberships in professional

organizations.”).

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Kumho Tire Co. v. Carmichael
526 U.S. 137 (Supreme Court, 1999)
United States v. Johnson
617 F.3d 286 (Fourth Circuit, 2010)
United States v. Phillip Brooks Barker
553 F.2d 1013 (Sixth Circuit, 1977)
United States v. Michael Robert Perkins
470 F.3d 150 (Fourth Circuit, 2006)
Belk, Incorporated v. Meyer Corporation, U.S.
679 F.3d 146 (Fourth Circuit, 2012)
United States v. Pansier
576 F.3d 726 (Seventh Circuit, 2009)
United States v. Jose Gutierrez
757 F.3d 785 (Eighth Circuit, 2014)
United States v. James Michael Farrell
921 F.3d 116 (Fourth Circuit, 2019)
United States v. Patrick Sutherland
921 F.3d 421 (Fourth Circuit, 2019)
United States v. Figueroa-Lopez
125 F.3d 1241 (Ninth Circuit, 1997)
Kopf v. Skyrm
993 F.2d 374 (Fourth Circuit, 1993)

Cite This Page — Counsel Stack

Bluebook (online)
United States v. Leonardo Muro, Counsel Stack Legal Research, https://law.counselstack.com/opinion/united-states-v-leonardo-muro-ca4-2019.