U.S. v. Malagon

In prosecution on drug conspiracy and drug distribution charges, Dist. Ct. did not commit clear error in allowing DEA agent to testify as expert with respect to drug trafficking practices and use of code words in recorded conversations with defendant. Agent provided sufficient foundation with respect to said testimony, where he indicated that he had been involved in hundreds of narcotics-related investigations and was familiar with codes used in such transactions, as well as drug prices in Chicago area. Moreover, agent explained meanings of said words and how his experience led to his conclusions as to meaning of code words. Also, Dist. Ct. properly allowed another DEA agent to testify as lay witness under Rule 701 relating to words defendant used in conversation with agent during drug transaction, since agent could properly testify as to his understanding of meaning of said words during conversation to which he was party.