## Facts

- At the San Juan, Puerto Rico airport, U.S. Customs officers used a K-9 unit to screen checked luggage for a flight to New York City.
- The dog alerted to two suitcases that had been checked under the name “Miguel Rivera”; both suitcases contained cocaine.
- A third checked bag, also checked under “Rivera,” contained no cocaine but had a handwritten identification tag listing “Pedro Felix” and an address associated with Hector Julio Felix Montas.
- The three bags carried consecutive baggage-claim numbers.
- Airline records showed that “Rivera” and “Felix” purchased their tickets at the same time, checked in and checked bags at the same time, and had adjacent seats on the flight.
- Customs inspectors went to the gate area, found Montas, and asked to see his ticket and boarding pass; the documents were in the name “Felix, P.” The inspectors detained him.
- While being watched, an inspector observed a crumpled piece of paper fall from Montas’s back; when told that something had fallen from him, Montas said, “Not me. That’s not mine.”
- The crumpled papers were the baggage-claim checks for all three bags, including the two that contained cocaine.
- Montas was charged with possession with intent to distribute cocaine and was convicted by a jury.
- At trial, the government called DEA Agent Ivan Rios, who testified based on his experience with airport drug cases; he stated that drug smugglers commonly use names other than their own on plane tickets and luggage.
- Montas objected to parts of Rios’s testimony as speculative, irrelevant, and improperly elicited, and argued that the “false names” point was within an average juror’s understanding; the trial court overruled the objections.

## Issues

1. Whether the evidence was sufficient to allow a rational jury to find beyond a reasonable doubt that Montas knowingly possessed cocaine with intent to distribute.
2. Whether the district judge’s questioning of a prosecution witness and comments to the prosecutor deprived Montas of a fair trial.
3. Whether the district court erred under Federal Rules of Evidence 702 and 403 by admitting Agent Rios’s testimony about drug couriers’ use of false names on airline tickets and luggage.

## Decision

- The First Circuit affirmed the conviction.
- The court held the evidence was sufficient: the consecutive claim tags, the connection between the luggage tag and Montas’s address, the joint travel arrangements with “Rivera,” and Montas’s possession and apparent discard of the claim checks supported an inference that he participated in the venture and knew the cocaine was in the luggage.
- The court concluded the trial judge’s interventions did not amount to reversible error when the record was considered as a whole; they did not convey judicial bias or deny a fair trial.
- The court acknowledged that “false names” testimony can be close to a “routine inference” jurors may draw without specialized knowledge and that such testimony can carry a risk of unfair prejudice by placing a law-enforcement witness’s authority behind the prosecution’s theory.
- Even so, the court held that admitting Rios’s testimony was within the trial court’s broad discretion under Rules 702 and 403 and did not amount to a manifest abuse of discretion warranting reversal.

## Legal Principles

- In reviewing sufficiency of the evidence, an appellate court views the evidence in the light most favorable to the verdict and asks whether a rational jury could find guilt beyond a reasonable doubt.
- A trial judge may ask questions and manage the presentation of evidence; reversal is warranted only when judicial conduct, viewed in context and in the full record, likely affected the trial’s fairness.
- Under Fed. R. Evid. 702, opinion testimony based on specialized knowledge is admissible if it helps the jury understand the evidence or determine a fact in issue; the trial court has wide latitude in making that call.
- Even if testimony satisfies Rule 702, Fed. R. Evid. 403 allows exclusion if probative value is substantially outweighed by the risk of unfair prejudice, confusion, or needless presentation; Rule 403 rulings are reviewed with substantial deference.
- Appellate review of admitting specialized-knowledge testimony is for manifest abuse of discretion; close evidentiary calls generally are left to the trial court unless the ruling is plainly unreasonable.

## Conclusion

The First Circuit upheld Montas’s conviction for possession with intent to distribute cocaine, finding that the government’s circumstantial proof—especially the consecutive baggage tags, the tie between a luggage tag and Montas’s address, coordinated travel with “Rivera,” and Montas’s possession and apparent disposal of the claim checks—allowed the jury to infer knowing participation in the smuggling scheme; the court also found no reversible prejudice from the judge’s trial management and held that admitting the DEA agent’s testimony about couriers’ use of false names fell within the district court’s discretion under Rules 702 and 403.


United States v. Montas, 41 F.3d 775 (1994)