United States v. Jesus Felix-Gutierrez

Jesus Felix-Gutierrez appeals his conviction for being an accessory after the fact. Felix was charged with assisting Rafaelo Caro-Quintero, who allegedly participated in the kidnapping and murder of DEA Special Agent Enrique Camarena-Salazar and Alfredo Zavala, in his effort to avoid capture by law enforcement authorities. Following a jury trial, Felix was convicted and sentenced to 10 years in prison. He raises several issues on appeal. We reject his claims and affirm the judgment of the district court.

I. Facts

This case arises out of the 1985 kidnapping, torture, and murder of DEA Special Agent Enrique Camarena and Alfredo Za-vala, a pilot who was a confidential DEA informant. Camarena and Zavala disappeared on February 7, 1985, in Guadalajara, Mexico. Approximately one month later, their bodies were found lying together in an open field near Zamora, Michoacan, Mexico. They had been brutally tortured and murdered.

During trial, the prosecution introduced evidence that Caro-Quintero, an alleged drug kingpin in Mexico, played a central role in the torture and murders of Camare-na and Zavala. Felix and his co-defendant, Rene Martin Verdugo-Urquidez, were associated with the…