United States v. Lyle

919 F.3d 716 (2019) United States Court of Appeals for the Second Circuit 2019-04-01

criminal appeal from conviction for conspiracy to distribute and possess with intent to distribute methamphetamine (21 U.S.C. ยง 846); sufficiency of conspiracy evidence affirmed (result: claimant-won)

Facts

  1. 2 Agreement of two or more persons to the unlawful object satisfied proved
    Because we conclude that the evidence at trial was sufficient to support all convictions, the challenged searches and seizures did not violate the Fourth Amendment, the admission of Lyle's statements did not violate the Fifth Amendment, and Van Praagh's sentence was reasonable, we affirm the judgments of the district court.
  2. 2 Agreement of two or more persons to the unlawful object satisfied proved
    Van Praagh regularly sold methamphetamine to Lyle, who was also a methamphetamine dealer in the New York area.
  3. 2 Agreement of two or more persons to the unlawful object satisfied proved
    The crux of a conspiracy is an agreement between two or more persons to join together to accomplish something illegal.
  4. 2 Agreement of two or more persons to the unlawful object satisfied proved
    Under this exception, "the existence of a buyer-seller relationship does not itself establish a conspiracy; however, where there is additional evidence showing an agreement to join together to accomplish an objective beyond the sale transaction, the evidence may support a finding that the parties intentionally participated in a conspiracy."
  5. 2 Agreement of two or more persons to the unlawful object satisfied proved
    The district court did not plainly err in failing to give a buyer-seller instruction because the government presented ample evidence of a narcotics conspiracy beyond a buyer-seller relationship between Van Praagh and Lyle.
  6. 2 Agreement of two or more persons to the unlawful object satisfied proved
    With assistance from Tarantino, he regularly sold methamphetamine out of his apartment in Queens as well as out of hotels, and he made deliveries to "[p]robably 50" customers.
  7. 2 Agreement of two or more persons to the unlawful object satisfied proved
    Tarantino testified that Lyle repeatedly purchased pound-level quantities of methamphetamine at $19,000 to $25,000 per pound.