U.S. v. Garcia-Avila

In prosecution on drug conspiracy charge, Dist. Ct. did not err in allowing expert to testify regarding true meaning of code words contained in recorded conversation between defendant and others that described terms of drug deal. Experts may testify as to meaning of such code words where, as here, instant expert based his testimony on his own knowledge of common practices in drug trade and not on any personal knowledge of underlying subject matter of recorded conversation. Dist. Ct. also did not commit reversible error in admitting evidence of defendant’s uncharged participation in prior ecstasy transaction, where: (1) one recorded conversation at issue in charged offense contained defendant’s reference to ecstasy; and (2) evidence of defendant’s involvement in charged methamphetamine transaction was overwhelming.