U.S. v. Hidalgo

Record contained sufficient evidence to support defendant’s drug conspiracy conviction, even though defendant argued that record showed, at best, existence of only buyer-seller relationship between defendant and his drug supplier. Jury could properly conclude that coded language between defendant and his drug supplier evidenced existence of course of conduct that involved extension of drugs on credit. Moreover, record supported fact that defendant sold drugs on consignment, that defendant acquired large quantities of drugs, and that defendant and his drug supplier had joint stake in drug operation so as to support drug conspiracy conviction. Also, venue was appropriate in Eastern District of Wisconsin, where defendant committee three overt drug-related acts in said District. Too, while Dist. Ct. abused its discretion in failing to give limiting instruction on admission of bill of lading into evidence, since said admission was on limited basis and not for truth of matters contained in bill of lading, error was harmless where contents of bill of lading did not advance case against defendant. Finally, Dist. Ct. committed plain error in admitting improper bolstering evidence that involved many steps government took to obtain wiretap. However, said error did not require reversal, where evidence against defendant was overwhelming.