United States v. Yuris Bonilla-Guizar

Defendants-Appellants, Yuris Bonilla-Guizar and Carlos Armando Calixtro-Bus-tamante, appeal their respective criminal convictions in a joint trial in the United States District Court for the District of Arizona (“district court”) as well as their subsequent sentences. Bonilla-Guizar (“Bonilla”) was convicted of conspiracy to commit hostage taking and harboring an alien. Calixtro-Bustamante (“Calixtro”) was convicted of conspiracy to commit hostage taking, hostage taking, and harboring an alien. Bonilla and Calixtro both object to the following district court rulings: (1) permitting a case agent to testify as an expert witness; and (2) denying Defendants’ request for a limiting instruction to the jury or other cautionary measure regarding the case agent’s testimony. With respect to his sentence, Bonilla objects to the district court’s application of a two-level enhancement, under U.S.S.G. § 3Bl.l(c), for his alleged leadership role in the criminal activity. Finally, both Bon-illa and Calixtro object to the district court’s application of a two-level sentencing enhancement, under U.S.S.G. § 2A4.1(b), for use of a dangerous weapon.

On appeal, we consider whether the…