U.S. v. Santiago

In prosecution on drug distribution and conspiracy charges based on controlled drug purchase, Dist. Ct. did not err in admitting references to defendant's gang membership made by various govt. witnesses. Said evidence was admissible to help explain terms used by confidential informant and third-party when setting up controlled purchase, and said evidence was relevant to demonstrate that defendant had more than buyer-seller relationship with drug supplier. Moreover, any error was harmless given fact that defendant was identified as participant at site of drug purchase.