U.S. v. Marchan

In prosecution on drug distribution charges, Dist. Ct. did not err in admitting testimony from multiple witnesses indicating that defendant had coordinated with third-party to purchase cocaine from third-party, even though defendant argued that such evidence constituted inadmissible hearsay. Said testimony did not constitute hearsay evidence, where it was presented only to show course of govt. investigation leading up to transaction at issue in charged offense. Also, Dist. Ct. did not violate defendant’s 6^th Amendment rights by limiting defendant’s ability to explore witness’ cooperation agreement with govt., as well as any mandatory minimum sentence witness might have avoided because of said agreement. Such limitation was appropriate where defendant was still able to address witness’ bias against him, and defendant’s suggestion that govt. inappropriately failed to attribute more cocaine to witness and charge him with more serious offense lacked any supportive evidence. Too, Dist. Ct. did not err in giving jury Spanish language audio-recording of drug transaction, where: (1) said recording had been properly admitted into evidence; (2) said recording provided additional information not presented in transcript; and (3) Dist. Ct. gave proper limiting instruction.