United States v. Jackson - 335 F.3d 170 (2d Cir. 2003)

Rule:

An appellate court reviews a district court's evidentiary rulings for abuse of discretion. The district court has broad discretion regarding the admission of evidence, and the court's evidentiary determinations will be reversed only if they are "manifestly erroneous." Generally, an appellate court will not overturn a district court's evidentiary rulings unless the court acted arbitrarily or irrationally.

Facts:

After a trial in the district court, a jury found defendant Charles L. Jackson guilty of conspiring to import 5 kilograms or more of cocaine into the United States. Although the district court denied Jackson's motion for acquittal as to the conspiracy, it granted Jackson's motion for acquittal as to the jury's drug quantity determination. The court concluded that Jackson was guilty of the lesser-included offense of conspiracy to import between 500 grams and 5 kilograms of cocaine. Jackson challenged his conviction on evidentiary grounds. He contended that the court abused its discretion in refusing to admit the entire plea allocution of co-conspirator Steve Brown. The Government cross-appealed the district court's grant of Jackson's motion of acquittal on drug quantity, contending that a reasonable jury could easily have found that Jackson's conspiracy involved at least 5 kilograms of cocaine.

Issue:

1. Did the district court abuse its discretion in refusing to admit the entire plea allocution of defendant’s co-conspirator?
2. Could a reasonable jury find that defendant’s conspiracy involved at least 5 kilograms of cocaine? 

Answer:

1) No. 2) Yes.

Conclusion:

The court noted that the district court has broad discretion regarding the admission of evidence, and the court's evidentiary determinations will be reversed only if they are "manifestly erroneous." Generally, the district court’s evidentiary rulings will not be overturned unless the court "acted arbitrarily or irrationally." In this case, the appellate court found that defendant's evidentiary challenges were meritless, and thus, affirmed defendant’s conviction. Anent the second issue, the court noted that under Rule 29, a district court will grant a motion to enter a judgment of acquittal on grounds of insufficient evidence if it concluded that no rational trier of fact could have found the defendant guilty beyond a reasonable doubt. In the instant case, the court found that the district court erred in granting defendant's Rule 29 motion because there was more than sufficient evidence for a jury to find that defendant conspired to import five or more kilograms of cocaine.