U.S. v. Richards

In prosecution on drug distribution charge, Dist. Ct. did not err in denying defendant’s motion to suppress cocaine seized from backpack in defendant’s car after police observed defendant’s vehicle stop briefly in garage of home of suspected high-level drug dealer. Police had probable cause to stop defendant’s vehicle where officer had purchased 10 kilograms at same house less than hour before defendant’s vehicle arrived at said house, and where defendant’s peculiar approach to house mirrored that of officer’s vehicle after both cars met another vehicle that led them to said house. Moreover, Dist. Ct. did not err in admitting phone calls defendant made to third-party that contained conversations about uncharged drug transactions where said evidence was introduced to show defendant’s knowledge about contents of backpack. However, new trial was required where prosecutor repeatedly called defendant drug dealer and drug trafficker during closing argument based upon said phone calls, and thus improperly urged jury to convict defendant based on his propensity to commit drug crimes.