U.S. v. Sanchez

In prosecution on conspiracy and attempted kidnapping charges, Dist. Ct. did not err in admitting evidence of uncharged drug trafficking conduct where charged offenses pertained to defendant’s attempt to kidnap two individuals who were witnesses in trial against drug leader. Subject evidence provided key factual background for charged offense and supplied jury motive for why victims were targeted. Fact that Dist. Ct. did not treat evidence of underlying drug trafficking activity as relevant conduct for purposes of calculating his sentencing-guideline range was irrelevant. Record, though, did not support defendant’s conviction on charge of conspiracy to retaliate against witnesses where there was no evidence that defendant knew that witnesses had testified against drug leader or that motive for kidnapping was to retaliate against them for their testimonies.