United States v. Miguel Diaz

CourtCourt of Appeals for the Fourth Circuit
DecidedSeptember 29, 2023
Docket22-4277
StatusUnpublished

This text of United States v. Miguel Diaz (United States v. Miguel Diaz) 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. Miguel Diaz, (4th Cir. 2023).

Opinion

USCA4 Appeal: 22-4277 Doc: 42 Filed: 09/29/2023 Pg: 1 of 8

UNPUBLISHED

UNITED STATES COURT OF APPEALS FOR THE FOURTH CIRCUIT

No. 22-4277

UNITED STATES OF AMERICA,

Plaintiff - Appellee,

v.

MIGUEL ANGEL COREA DIAZ, a/k/a Reaper,

Defendant - Appellant.

No. 22-4305

JUNIOR NOE ALVARADO-REQUENO, a/k/a Insolente, a/k/a Trankilo,

Appeals from the United States District Court for the District of Maryland, at Greenbelt. Paula Xinis, District Judge. (8:17-cr-00382-PX-13; 8:17-cr-00382-PX-5)

Submitted: April 25, 2023 Decided: September 29, 2023 USCA4 Appeal: 22-4277 Doc: 42 Filed: 09/29/2023 Pg: 2 of 8

Before AGEE, WYNN, and RUSHING, Circuit Judges.

Affirmed by unpublished per curiam opinion.

ON BRIEF: Stephen B. Mercer, RAQUINMERCER LLC, Rockville, Maryland, for Appellant Miguel Angel Corea Diaz. Marc G. Hall, LAW OFFICE OF MARC G. HALL, P.C., Greenbelt, Maryland, for Appellant Junior Noe Alvarado-Requeno. Erek L. Barron, United States Attorney, Baltimore, Maryland, Timothy F. Hagan, Jr., Assistant United States Attorney, OFFICE OF THE UNITED STATES ATTORNEY, Greenbelt, Maryland, for Appellee.

Unpublished opinions are not binding precedent in this circuit.

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PER CURIAM:

After a four-week trial, a jury convicted Miguel Angel Corea Diaz and Junior Noe

Alvarado-Requeno, two members of the MS-13 gang, of RICO conspiracy, conspiracy to

commit murder in aid of racketeering, murder in aid of racketeering, and drug-related

counts. On appeal, Defendants challenge only the district court’s evidentiary rulings

allowing the testimony of three witnesses. Finding no error, we affirm.

We review a district court’s evidentiary rulings for abuse of discretion and “will

only overturn an evidentiary ruling that is arbitrary and irrational.” United States v. Cole,

631 F.3d 146, 153 (4th Cir. 2011) (internal quotation marks omitted). “To that end, we

look at the evidence in a light most favorable to its proponent, maximizing its probative

value and minimizing its prejudicial effect.” Id. (internal quotation marks omitted). For

evidentiary rulings under Federal Rule of Evidence 403, we review the district court’s

decision for “plain abuse of discretion” and “may overturn a district court’s Rule 403

decision only under the most extraordinary circumstances.” United States v. Miller, 61

F.4th 426, 430 (4th Cir. 2023) (internal quotation marks omitted).

Defendants first challenge the district court’s decision to allow Kenia Anali Duarte-

Lopez to testify about statements her son, Anner, made to her before he was murdered.

The district court admitted Anner’s statements as statements against interest under Federal

Rule of Evidence 804(b)(3). Under this rule, hearsay may be admitted “if (1) the declarant

is unavailable, (2) the statement is genuinely adverse to the declarant’s penal interest, and

(3) corroborating circumstances clearly indicate the trustworthiness of the statement.”

United States v. Bumpass, 60 F.3d 1099, 1102 (4th Cir. 1995) (internal quotation marks

3 USCA4 Appeal: 22-4277 Doc: 42 Filed: 09/29/2023 Pg: 4 of 8

omitted). “[W]hether a statement is self-inculpatory or not can only be determined by

viewing it in context.” Williamson v. United States, 512 U.S. 594, 603 (1994). And to

evaluate whether a self-inculpatory statement is sufficiently trustworthy, we consider

factors such as “the declarant’s motive in making the statement and whether there was a

reason for the declarant to lie,” “the party or parties to whom the statement was made,” and

“the relationship of the declarant with the accused.” United States v. Dargan, 738 F.3d

643, 650 (4th Cir. 2013) (internal quotation marks omitted). Upon review, we conclude

that Anner was unavailable to testify because he was murdered, Anner’s statements were

self-inculpatory because he implicated himself in MS-13’s extortion efforts and as an

accessory to a homicide, and that the surrounding circumstances indicate the statements

were trustworthy. A reasonable person would not make self-inculpatory statements such

as Anner’s unless he believed them to be true. The district court did not abuse its discretion

by allowing Duarte-Lopez to testify about Anner’s out-of-court statements to her.

Next, Defendants argue that the district court impermissibly allowed Detective

Jorge Garcia to testify as an expert about the structure, hierarchy, rules, symbols, and

general activities of MS-13 in Maryland. Specifically, they argue the district court’s

admission of this testimony ran afoul of Federal Rules of Evidence 702 and 403.

Rule 702 allows testimony by a “witness who is qualified as an expert by

knowledge, skill, experience, training, or education” so long as “(a) the expert’s scientific,

technical, or other specialized knowledge will help the trier of fact to understand the

evidence or to determine a fact in issue; (b) the testimony is based on sufficient facts or

data; (c) the testimony is the product of reliable principles and methods; and (d) the expert

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has reliably applied the principles and methods to the facts of the case.” Fed. R. Evid. 702.

Under this rule, “a district court must ensure that the expert is qualified and that the expert’s

testimony is both relevant and reliable.” United States v. Smith, 919 F.3d 825, 835 (4th

Cir. 2019). However, the district court “is not intended to serve as a replacement for the

adversary system, and consequently, the rejection of expert testimony is the exception

rather than the rule.” Id. (internal quotation marks omitted). Additionally, Rule 403 allows

a district court to “exclude relevant evidence if its probative value is substantially

outweighed by a danger of . . . unfair prejudice.” Fed. R. Evid. 403. In criminal cases,

unfairly prejudicial evidence “speaks to the capacity of some concededly relevant evidence

to lure the factfinder into declaring guilt on a ground different from proof specific to the

offense charged.” Old Chief v. United States, 519 U.S. 172, 180 (1997).

We discern no abuse of discretion in allowing Detective Garcia to testify as an

expert on MS-13 in Maryland. “[O]ur practice” is generally to “allow[] expert testimony

on gang communications, structures, and practices.” United States v. Zelaya, 908 F.3d

920, 930 (4th Cir. 2018). Similar to other cases where witnesses have properly testified as

experts on MS-13, Detective Garcia had years of law enforcement experience that qualified

him to testify as an expert. His experience included investigating crimes involving MS-13

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