United States v. Reginald Anderson

Court of Appeals for the Eleventh Circuit·Decided January 6, 2025·No. 22-10619·Unpublished

Opinion

[DO NOT PUBLISH]

In the

United States Court of Appeals For the Eleventh Circuit

No. 22-10619

Non-Argument Calendar

UNITED STATES OF AMERICA, Plaintiff-Appellee,

versus REGINALD ANDERSON, a.k.a. Red,

Defendant-Appellant.

Appeal from the United States District Court for the Southern District of Georgia D.C. Docket No. 4:19-cr-00183-RSB-CLR-1

2 Opinion of the Court 22-10619

Before LAGOA, BRASHER, and WILSON, Circuit Judges. PER CURIAM:

Reginald Anderson was convicted of three counts of distribution of methamphetamine, see 21 U.S.C. §§ 841(a)(1), (b)(1)(C), after selling it three times to confidential informants working for the Drug Enforcement Administration.

The conduct and evidence underlying Anderson’s convictions are straightforward, so we do not recite in detail the factual or procedural background of this case. Instead, relevant here, a grand jury indicted Anderson on three counts of drug distribution based on three drug transactions—one per count—that he made with the confidential informants. The first two transactions took place the morning and afternoon of June 5, 2018. The third occurred on June 12, 2018. A jury convicted Anderson of all three counts after seeing exhibits collected from each transaction, that DEA chemists confirmed were methamphetamine; after hearing the confidential informants testify about each transaction; and after seeing audio-video recordings and transcripts of the last two transactions .

On appeal, Anderson does not challenge any of the evidence above. Instead, he first challenges the district court’s decision to permit a DEA agent to testify as an expert and offer testimony that he argues was improper on several grounds. Second, he challenges the district court’s denial of his motion for mistrial after

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government witnesses implied that he was involved in prior drug transactions outside this case. Third, he argues that his convictions should be reversed because the government committed prosecutorial misconduct during its closing argument and the district court failed to take curative action after that misconduct. Fourth, he argues that these errors cumulatively warrant a reversal of his convictions . For the reasons below, each challenge fails, and we affirm.

I.

We begin with Anderson’s challenges to a DEA agent’s testimony . At trial, the government called Robert Livingston, a DEA agent who worked with the confidential informants to set up the transactions underlying Anderson’s drug distribution convictions. On appeal, Anderson contends that the district court should not have permitted Livingston to (1) testify as an expert and (2) provide testimony that Anderson alleges is hearsay, improper identification testimony, and testimony violating the Confrontation Clause.

Three standards of review apply. First, we review a district court’s “evidentiary rulings on the admission of expert witness testimony for abuse of discretion.” United States v. Jayyousi, 657 F.3d 1085, 1106 (11th Cir. 2011) (cleaned up). Similarly, we review “a district court’s decisions regarding the admissibility of evidence and testimony for abuse of discretion.” United States v. Hawkins, 934 F.3d 1251, 1264 (11th Cir. 2019). A district court has considerable leeway in its evidentiary rulings, see United States v. Barton, 909 F.3d 1323, 1330 (11th Cir. 2018), and abuses its discretion when it “applies an incorrect legal standard or makes findings of fact that are

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clearly erroneous.” United States v. Azmat, 805 F.3d 1018, 1041 (11th Cir. 2015) (cleaned up). Importantly, an abuse of discretion will not warrant reversal “unless the objecting party has shown a substantial prejudicial effect from the ruling.” Barton, 909 F.3d at 1330–31 (cleaned up). “Substantial prejudice goes to the outcome of the trial,” and “where an error had no substantial influence on the outcome , and sufficient evidence uninfected by error supports the verdict , reversal is not warranted.” Id. at 1331 (cleaned up).

Second, if a defendant fails to preserve an issue below, we review the issue for plain error. See Hawkins, 934 F.3d at 1264. “To establish plain error, a defendant must show (1) error; (2) that is plain; (3) that affects his substantial rights; and (4) that seriously affects the fairness, integrity, or public reputation of judicial proceedings .” United States v. Lewis, 40 F.4th 1229, 1246 (11th Cir. 2022). To establish that an error affected his substantial rights—the third prong of the plain error test—a defendant must establish “a reasonable probability that, but for the error, a different outcome would have occurred.” United States v. Margarita Garcia, 906 F.3d 1255, 1267 (11th Cir. 2018).

Third, we review de novo whether testimony violates the Confrontation Clause. United States v. Kent, 93 F.4th 1213, 1217 (11th Cir. 2024). With these three standards in mind, we address— and reject—Anderson’s arguments on Livingston’s testimony.

A.

We first address Anderson’s argument that the court should not have permitted Livingston to testify as an expert. At trial, the

22-10619 Opinion of the Court 5

government sought to qualify Livingston as an expert in “drug trafficking and distribution.” Anderson objected that Livingston would be unable to provide information not already “within the ken of the jury.” The district court overruled the objection and permitted Livingston to testify as an expert. In so doing, the court did not abuse its discretion.

Federal Rule of Evidence 702 permits expert testimony if specialized knowledge will help the jury to understand the evidence or to determine a fact in issue.” United States v. Garcia, 447 F.3d 1327, 1334 (11th Cir. 2006) (cleaned up). And a witness can be qualified as an expert, based on his knowledge, skill, experience, training, or education. See id. at 1335.

Here, Livingston was qualified to testify as an expert in drug trafficking and distribution, and his testimony was helpful to the jury. Livingston had extensive experience, training, and knowledge in drug operations: he was a DEA agent for over 20 years, received training in drug code and surveillance methods, and conducted dozens if not hundreds of narcotics investigations. See id. at 1332, 1335 (district court did not abuse its discretion in permitting a witness to testify as an expert in drug distribution when the witness was a DEA agent for several years, received training on the operation of drug organizations, and was involved in at least 50 drug investigations ). And Livingston’s testimony—which covered controlled purchases and the meanings of code terms used in drug trades—helped the jury understand the drug distribution evidence underlying Anderson’s convictions. See Hawkins, 934 F.3d at 1261

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(we have “repeatedly” held that “narcotics agents may testify as experts to help juries understand the drug business, codes, and jargon ”); Garcia, 447 F.3d at 1334 (the “operations of narcotics dealers are a proper subject for expert testimony under Rule 702” (cleaned up)).

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