United States v. Ricardo Garza

Ricardo Garza appeals his convictions following a jury trial at which he was found guilty of one count of conspiracy to distribute cocaine, in violation of 21 U.S.C. §§ 841 (a)(1) and 846, and one count of distribution of cocaine, in violation of 21 U.S.C. § 841 (a)(1). Garza contends the district court erred by: (1) denying his motion to suppress evidence resulting from his arrest because his arrest was not supported by probable cause; (2) denying his motion to suppress evidence seized pursuant to an allegedly defective search warrant; (3) denying his motion to dismiss the conspiracy count for insufficient evidence; (4) denying his motion to dismiss the distribution count for insufficient evidence; (5) improperly admitting into evidence hearsay statements of alleged co-conspirators; (6) improperly instructing the jury on the conspiracy count; (7) improperly instructing the jury on the distribution count; and (8) improperly instructing the jury on “reasonable doubt.” We have jurisdiction under 28 U.S.C. § 1291 and we affirm.

I

Probable Cause to Support the Arrest

Garza contends that police officers had no probable cause to arrest him and that all evidence derived from his…