United States v. Ortega

CourtCourt of Appeals for the Second Circuit
DecidedMarch 12, 2025
Docket23-7417
StatusUnpublished

This text of United States v. Ortega (United States v. Ortega) 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. Ortega, (2d Cir. 2025).

Opinion

23-7417 United States v. Ortega

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 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 12th day of March, two thousand twenty-five.

Present: MICHAEL H. PARK, SARAH A. L. MERRIAM, Circuit Judges.* ________________________________________

UNITED STATES OF AMERICA,

Appellee,

v. 23-7417

BILLY ORTEGA, AKA JASON, AKA SEALED DEFENDANT 1,

Defendant-Appellant. † __________________________________________

FOR APPELLEE: MICHAEL HERMAN (Micah Fergenson, James Ligtenberg, on the brief), Assistant United States Attorneys, for Damian Williams, United States Attorney for the Southern District of New York, New York, NY.

* Judge Denny Chin, originally a member of the panel, recused himself from consideration of this appeal. The two remaining members of the panel have determined the matter. See 2d Cir. IOP E(b). † The Clerk of Court is respectfully directed to amend the caption accordingly. FOR DEFENDANT-APPELLANT: B. ALAN SEIDLER, New York, NY.

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

York (Abrams, J.).

UPON DUE CONSIDERATION, IT IS HEREBY ORDERED, ADJUDGED, AND

DECREED that the judgment of the district court is AFFIRMED.

On January 30, 2023, a jury found Billy Ortega guilty of: one count of participating in a

narcotics- trafficking conspiracy that resulted in death, in violation of 21 U.S.C. § 846; three counts

of distributing narcotics that resulted in death, and aiding and abetting the same, in violation of 21

U.S.C. §§ 841(a)(1), 841(b)(1)(C), and 18 U.S.C. § 2; and one count of using and carrying a

firearm during and in relation to, or possessing a firearm in furtherance of, the narcotics trafficking

conspiracy, and aiding and abetting the same, in violation of 18 U.S.C. §§ 924(c)(1)(A)(i) and 18

U.S.C. § 2. On appeal, Ortega argues that the jury’s finding that the drugs he distributed caused

the victims’ deaths was not supported by sufficient evidence, the district court erred in excluding

the testimony of Jonathan DeLaura, and the district court constructively amended the indictment

when it instructed the jury that it could convict based on an aiding and abetting theory of liability.

We assume the parties’ familiarity with the underlying facts, procedural history of the case,

and issues on appeal.

I. Sufficiency of the Evidence

Ortega argues that his conviction should be reversed because the evidence was insufficient

to prove that the drugs he distributed caused the deaths of Julia Ghahramani, Amanda Scher, and

Ross Mtangi. “We review de novo challenges to the sufficiency of the evidence.” United States

v. Sabhnani, 599 F.3d 215, 241 (2d Cir. 2010). In reviewing such a claim, “we view the evidence

2 in the light most favorable to the government, drawing all inferences in the government’s favor

and deferring to the jury’s assessments of the witnesses’ credibility.” Id. (quoting United States

v. Parkes, 497 F.3d 220, 225 (2d Cir. 2007)). A jury verdict must be upheld if “any rational trier

of fact could have found the essential elements of the crime beyond a reasonable doubt.”

Jackson v. Virginia, 443 U.S. 307, 319 (1979). The standard of review is “exceedingly

deferential,” United States v. Hassan, 578 F.3d 108, 126 (2d Cir. 2008), and “[a] defendant

challenging the sufficiency of the evidence bears a heavy burden,” United States v. Kozeny, 667

F.3d 122, 139 (2d Cir. 2011).

This Court’s deference to the jury is “especially important” in the context of conspiracy

convictions because “a conspiracy by its very nature is a secretive operation, and it is a rare case

where all aspects of a conspiracy can be laid bare in court.” United States v. Jackson, 335 F.3d

170, 180 (2d Cir. 2003) (quoting United States v. Pitre, 960 F.2d 1112, 1121 (2d Cir. 1992)).

“[A] defendant’s knowledge of the conspiracy and his participation in it with criminal intent,” for

example, “may be established through circumstantial evidence.” United States v. Gordon, 987

F.2d 902, 906-07 (2d Cir. 1993).

At trial, the government presented ample evidence that Ortega’s drugs caused the deaths

of Ghahramani, Scher, and Mtangi. Through the testimony of 16 witnesses and the introduction

of over 350 exhibits, the government established that all three victims separately ordered cocaine

from Ortega on March 17, 2021. United States v. Ortega, No. 22-CR-91, 2023 WL 6140929, at

*2 (S.D.N.Y. Sept. 20, 2023). Even though Ortega knew that his batch of cocaine was “really

strong,” he dispatched Kaylen Rainey to deliver the cocaine to the victims in black translucent

zipper-lock bags. Id. All three victims died shortly after receiving the cocaine. Id. They

3 each had fentanyl in their blood, and their bodies were found near Ortega’s black zipper-lock bags.

Id. Furthermore, the government’s expert medical toxicologist testified that “fentanyl overdose

was the ‘but for’ cause of death for Ghahramani, Scher, and Mtangi.” Id. In short, there was

sufficient evidence for a rational trier of fact to conclude that the drugs distributed by Ortega

caused the victims’ deaths.

II. DeLaura’s Testimony

Ortega contends that the testimony of DeLaura was improperly excluded at trial. “We

review a trial court’s evidentiary rulings deferentially, and we will reverse only for abuse of

discretion,” which requires a determination “that the challenged evidentiary rulings were arbitrary

and irrational.” United States v. Quinones, 511 F.3d 289, 307-08 (2d Cir. 2007) (internal

quotation marks omitted). An evidentiary error is “harmless if we can conclude with fair

assurance that the jury’s judgment was not substantially swayed by the error.” United States v.

Paulino, 445 F.3d 211, 219 (2d Cir. 2006) (internal quotation marks omitted). Here, the district

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Related

United States v. Sabhnani
599 F.3d 215 (Second Circuit, 2010)
United States v. Quinones
511 F.3d 289 (Second Circuit, 2007)
United States v. Parkes
497 F.3d 220 (Second Circuit, 2007)
Jackson v. Virginia
443 U.S. 307 (Supreme Court, 1979)
United States v. Rupert Gordon
987 F.2d 902 (Second Circuit, 1993)
United States v. Timothy M. Mucciante
21 F.3d 1228 (Second Circuit, 1994)
United States v. Christian Paulino
445 F.3d 211 (Second Circuit, 2006)
United States v. D’Amelio
683 F.3d 412 (Second Circuit, 2012)
United States v. Hassan
578 F.3d 108 (Second Circuit, 2009)
United States v. Kozeny
667 F.3d 122 (Second Circuit, 2011)
United States v. Dove
884 F.3d 138 (Second Circuit, 2018)

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