Deel

MEMORANDUM *

The district court did not err by denying Deel’s motion to dismiss for lack of jurisdiction over the charge of discharging a firearm during a crime of violence, 18 U.S.C. § 924 (c)(1)(A). Even though that crime is not enumerated in the Major Crimes Act, the court’s jurisdiction was firmly established by United States v. *283 Laughing, 855 F.2d 659, 660 (9th Cir. 1988).

The district court did not err by admitting the rifle cartridge into evidence. A search warrant was not required because the cartridge in the seat of the car was in plain view from outside the car, and there was probable cause to believe that it was evidence of a crime. See United States v. Seljan, 547 F.3d 993, 1005 (9th Cir.2008). Generally speaking, an automobile can be searched without a warrant if there is probable cause to believe it contains contraband or evidence of a crime. United States v. Hatley, 15 F.3d 856, 858-59 (9th Cir.1994).

The FBI agent’s testimony was admissible to impeach the government’s witness with his prior inconsistent statements. See United States v. Higa, 55 F.3d 448, 452 (9th Cir.1995). The district court properly instructed the jury on the limited purpose of the…