U.S. v. Bell

In prosecution on drug distribution charge, Dist. Ct. did not abuse its discretion in admitting letter drafted by defendant asking third-party to corroborate defendant's defense that he gave diets pills to police informant instead of drugs, and that defendant had eschewed drug lifestyle. Ct rejected defendant's argument that admission of said letter violated Rule 608(b) under plain error standard and further found that letter was relevant on issues of defendant's credibility and consciousness of guilt. Moreover, Dist. Ct. could properly admit testimony from third-party that defendant solicited him to cook crack cocaine even though defendant argued that said testimony constituted improper propensity evidence. Ct also found that Fair Sentencing Act signed in to law on August 3, 2010 was not retroactive.