United States v. Victor Corona

Victor Corona appeals his conviction and sentence for conspiracy to possess and dis tribute cocaine and three substantive counts stemming from this conspiracy. Corona was tried in the District of Nevada, which is where Corona’s coconspirators initially agreed to the drug transaction. The actual distribution, which formed the basis for the three substantive counts, took place in California. Among the issues Corona raises is the propriety of venue in Nevada for these substantive crimes. We reverse Corona’s convictions on counts two through four for improper venue, but we affirm the conspiracy conviction.

I

BACKGROUND

Josiah Speeht, a confidential informant, and Scott Jackson, an undercover agent, met with two of Corona’s coconspirators, Richard Carrillo and Ernest Benavidez, in Reno, Nevada on November 2, 1991. Benavidez agreed to supply ten kilograms of cocaine. Benavidez was supposed to meet Agent Jackson in Las Vegas on November 14 to conclude the transaction, but at the last minute, he called Jackson and said he could not travel to Las Vegas. The deal was postponed to November 26, and Benavidez agreed to bring the cocaine to Specht’s apartment in Corona, California.

On…