United States v. Isaac Bonelli

MEMORANDUM

Isaac Bonelli appeals his convictions for violation of 18 U.S.C. §§ 922 (g)(4) and 924(a)(2), Prohibited Possessor in Possession of Firearms, and 18 U.S.C. §§ 922 (u) and 924(f)(1), Theft from a Federal Firearm Licensee. The first conviction was the result of a jury trial and the second was pursuant to a plea of guilty. We have jurisdiction under 28 U.S.C. § 1291 and we affirm.

1. Bonelli contends that the district court abused its discretion in allowing the testimony of government expert MacMas-ter. The only legitimate purpose of Mac-Master’s testimony was that the stolen DPMS rifle had previously traveled in interstate commerce. His testimony, however, also included a discussion of firearms trafficking and Mexican cartels, a detailed description of the DPMS rifle’s characteristics, and a similar description of a second firearm that was not charged in the indictment.

We review the district court’s evidentiary rulings for abuse of discretion. United States v. Hieng, 679 F.3d 1131, 1135 (9th Cir. 2012). Evidentiary rulings to which no objection was made below are reviewed for plain error. Id. We “must reverse a conviction based on an erroneous evidentiary ruling…