USA v. Fernandez-Avalos, et al.

2008 DNH 211
CourtDistrict Court, D. New Hampshire
DecidedDecember 18, 2008
Docket07-CR-252-JD
StatusPublished

This text of 2008 DNH 211 (USA v. Fernandez-Avalos, et al.) is published on Counsel Stack Legal Research, covering District Court, D. New Hampshire primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
USA v. Fernandez-Avalos, et al., 2008 DNH 211 (D.N.H. 2008).

Opinion

USA v . Fernandez-Avalos, et a l . 07-CR-252-JD 12/18/08 UNITED STATES DISTRICT COURT FOR THE DISTRICT OF NEW HAMPSHIRE

United States of America v. Criminal N o . 07-252-JD Opinion N o . 2008 DNH 211 Eduardo K. Fernandez-Avalos and Maria C . Rosario

O R D E R

Codefendants Eduardo K. Fernandez-Avalos and Maria C .

Rosario (“Rosario”), are charged with conspiracy to structure

financial transactions in violation of 31 U.S.C. § 5324(a)(3).

Before the court is Rosario’s motion in limine to exclude a

witness’s identification of her from a photographic array. With

her motion, Rosario submitted a copy of the photographic array

and an excerpt from the United States Department of Justice’s

handbook of recommended practices. The government objects to the

exclusion. With its objection, the government submitted a

suspicious transaction report completed by the witness, a memo

from the investigating agent regarding the photo identification,

and the Drug Enforcement Agency’s Report of Investigation

completed by the investigating agent. Upon an order from the

court, the government also submitted the original photographic

array. I. Background

The following findings of fact are based upon the above

listed materials. On February 1 7 , 2006, two men and a woman

entered the United States Post Office in Atkinson, New Hampshire,

where the woman and one of the men separately purchased three

money orders in the amounts of $1000, $1000, and $995. The three

individuals left together and drove away in a car with a

Massachusetts license plate. Earlier that day, a nearly

identical occurrence was reported at the post office in Plaistow,

New Hampshire, and several similar transactions occurred at post

offices in Massachusetts on February 16 and 1 7 . Together, the

money orders purchased by the trio over the two days totaled more

than $40,000.

Each of the clerks in New Hampshire who sold the money orders to these individuals filled out a Suspicious Activity

Report, which, among other things, described the individuals. In

her report, the Plaistow clerk described the woman as “a Hispanic

female, approximately 5'1" - 5'2", with brown slightly curly hair

and average build.” United States Objection, Ex. 3 , ¶ 1 3 . The

Atkinson clerk’s report described the woman she saw as “of

Hispanic origin,” “45-50” years old, and “5'4" [/] 135 lbs.”

Id., Ex. 1 . The reports also provided a license plate number for

2 the car.

Postal Inspector John J. Stassi investigated these

activities and discovered that the car described in the reports

was owned by Enterprise Rent-A-Car and had been rented to Rosario

on February 2 , 2006, and returned on February 1 7 , 2006. A copy

of Rosario’s driver’s license photo was obtained from the Florida

Department of Motor Vehicles and included in a photographic

identification line-up containing photos of seven other women.

On July 2 5 , 2006, Postal Inspector John Stassi presented the

photographic line-up to the clerk at the Atkinson Post Office who

sold the money orders to the woman on February 1 7 , 2006. The

clerk identified Rosario as the woman who purchased the money

orders; she initialed and dated Rosario’s photo, and agreed to

testify in court regarding her identification. That same day,

Inspector Stassi presented a photographic lineup to the clerks at the Plaistow Post Office, but neither clerk could identify the

woman who had purchased the money orders. Inspector Stassi

recorded these events in his Report of Investigation prepared on

July 2 7 , 2006.

On December 1 2 , 2007, Rosario and Fernandez were charged in

a federal indictment with conspiracy to structure financial

transactions in violation of 31 U.S.C. § 5324(a)(3). Rosario and

Fernandez were arrested at Fernandez’s home in Miami on December

3 1 8 , 2007.

II. Applicable Legal Standard

Under the Due Process Clause of the United States

Constitution,“out-of-court identification based on a photo array”

will be suppressed only if the identification procedure was

“impermissibly suggestive,” and the suggestiveness “‘g[a]ve rise

to a very substantial likelihood of misidentification.’” United

States v . Holliday, 457 F.3d 1 2 1 , 125 (1st Cir. 2006) (quoting

Neil v . Biggers, 409 U.S. 1 8 8 , 197 (1972)). Identification

evidence will be suppressed “‘only in extraordinary cases.’”

Holliday, 457 F.3d at 125 (1st Cir. 2006) (quoting United States

v . Henderson, 320 F.3d 9 2 , 100 (1st Cir. 2003)). “In most cases,

the jury is capable of assessing the appropriate weight to be

given to identification evidence.” United States v . Bouthot, 878

F.2d 1506, 1516 n.11 (1st Cir. 1989).

The admissibility of an out-of-court identification based on

a photo array involves a two-part test. The defendant must first

demonstrate that the procedure is impermissibly suggestive.

United States v . Guzman-Rivera, 990 F.2d 6 8 1 , 682 (1st Cir.

1993). The court will examine “the suggestiveness of the

identification, and . . . whether there was some good reason for

the failure to resort to less suggestive procedures.” Holliday,

4 457 F.3d at 125 (internal quotation marks omitted). The court

may consider the number of individuals included in the array who

bear similarities with the suspect, id. at 126, placement of the

photograph within the array, and whether other conduct by the

police emphasized the defendant’s photograph, United States v .

Flores, 149 F.3d 1272, 1279 (10th Cir. 1998). The First Circuit has recognized that photos of individuals which contain slightly

darker or lighter backgrounds, or photos which depict persons

with skin pigmentations slightly different from the suspect do

not rise to the level of impermissible suggestiveness prohibited

by the Due Process Clause. See United States v . Brennick, 405

F.3d 9 6 , 100 (1st Cir. 2005).

If the photo array is deemed impermissibly suggestive, the

court must then address “whether, under the totality of the

circumstances, the suggestiveness is such that there is a very substantial likelihood of irreparable misidentification.”

Bouthot, 878 F.2d at 1514. The court will consider the following

factors: “the opportunity of the witness to view the criminal at

the time of the crime, the witness’ degree of attention, the

accuracy of his prior description of the criminal, the level of

certainty demonstrated at the confrontation, and the time between

the crime and the confrontation.” Id.

5 III.

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

Related

Cite This Page — Counsel Stack

Bluebook (online)
2008 DNH 211, Counsel Stack Legal Research, https://law.counselstack.com/opinion/usa-v-fernandez-avalos-et-al-nhd-2008.