U.S. v. Hamden

In prosecution on 2014 drug distribution and manufacture of synthetic cannabinoid, Dist. Ct. did not abuse its discretion in quashing defendant’s subpoena of two police officers involved in defendant’s 2012 charge for possession of different synthetic cannabinoid, where 2012 charge was ultimately dismissed, even though defendant argued that said evidence was necessary to support his claim that he did not believe that synthetic cannabinoids were illegal. Defendant’s proposed testimony from police officers was irrelevant, since 2012 arrest concerned different synthetic cannabinoid and was too remote to provide meaningful insight into defendant’s mental state in 2014. Also, Dist. Ct.’s ruling did not deprive defendant of opportunity to present his theory of defense, since Dist. Ct. allowed defendant opportunity to proffer evidence relevant to his 2014 knowledge of legal status of instant synthetic cannabinoid.