## Facts

- A federal grand jury charged Clifford Jones with knowingly and intentionally distributing heroin in violation of 21 U.S.C. § 841(a)(1).
- A jury convicted Jones in federal district court.
- At trial, the government offered heroin evidence contained in a lock-seal envelope.
- The agent who obtained the heroin testified that he transported it to Kansas City, Missouri, placed it in a lock-seal envelope, and mailed it to a forensic laboratory by certified mail.
- The agent also testified that the narcotics offered at trial were in the same condition as when he received them.
- At the laboratory, an evidence technician initially received the envelope and placed it in an evidence vault, but that technician did not testify at trial.
- A laboratory chemist testified that he removed the sealed envelope from the vault, conducted chemical testing, confirmed the substance was narcotics, then placed the narcotics and the original lock-seal envelope into a second lock-seal envelope and returned it to the vault.
- During jury selection, some prospective jurors disclosed prior personal experiences with narcotics problems; after voir dire, the jurors seated stated they could be fair and impartial.
- On appeal, Jones argued that (1) the jurors’ narcotics-related experiences required disqualification for implied bias, and (2) the heroin should have been excluded because the government did not establish an adequate chain of custody without testimony from the laboratory evidence technician who first received and stored it.

## Issues

1. Whether the seating of jurors who had prior personal experiences with narcotics required reversal on an implied-bias theory when voir dire revealed no actual bias.
2. Whether the district court erred in admitting the heroin exhibits when the government did not call the laboratory evidence technician who initially received and stored the sealed envelope.

## Decision

- The Eighth Circuit affirmed Jones’s conviction.
- The court rejected a per se implied-bias rule based on jurors’ prior narcotics-related experiences and found no actual bias on the record after voir dire.
- The court held the chain of custody was sufficient and the district court did not abuse its discretion in admitting the heroin; the government was not required to call every person who handled the evidence where the proof supported a reasonable probability that the exhibit was not materially changed.

## Legal Principles

- A juror is not automatically disqualified merely because of prior personal experiences related to the subject matter of the trial; absent proof of actual bias, a conviction will not be reversed on a per se implied-bias theory.
- Chain-of-custody proof for physical evidence is adequate when, considering the nature of the item and the circumstances of custody and preservation, the trial judge can find a reasonable probability that the exhibit has not been changed in any important respect.
- The government need not present testimony from every custodian in the chain; gaps generally affect the weight of the evidence rather than admissibility, unless there is a meaningful showing of alteration or tampering.
- A trial court’s admission of physical evidence based on chain-of-custody proof is reviewed for abuse of discretion.

## Conclusion

United States v. Jones upheld a heroin distribution conviction, holding that jurors’ prior narcotics-related experiences did not require disqualification without evidence of actual bias and that the heroin was properly admitted because the government established a reasonable-probability chain of custody even though the laboratory evidence technician who initially received the sealed envelope did not testify.


United States v. Jones, 486 F.2d 476 (1973)