U.S. v. Medrano

Defendant was not entitled to new trial on drug conspiracy and drug distribution charges, even though defendant asserted that Dist. Ct. erred in admitting screenshots of text message between defendant and third party that defendant claimed was inadmissible hearsay evidence. While Dist. Ct. admitted subject text message as exception to hearsay rule under section 801(d)(2)(E) as statement made by co-conspirator, any error in admitting said text message could be deemed as non-constitutional error that was subject to harmless error analysis. Moreover, admission of subject text message was harmless, where record contained overwhelming evidence of defendant’s guilt on charged offenses that included multiple sets of text messages between defendant and other members of charged conspiracy that discussed drug trafficking, witnesses who testified as to how defendant and others used post office to further conspiracy and who testified as to defendant and others selling drugs on multiple occasions, and evidence of drugs and drug paraphernalia taken from defendant’s hotel rooms.