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Ninth U.S. Circuit Overturns Conviction in Case Involving Teenager’s Deadly Fentanyl Overdose
By a MetNews Staff Writer
The Ninth U.S. Circuit Court of Appeals has overturned the conviction of a man charged with distributing fentanyl-laced pills that killed a Palos Verdes-area teenager, finding the trial judge erred in excluding evidence that another purported dealer, who contacted the minor before his death, had previously sold counterfeit pills containing that same substance and had in his contacts the names of 50 people who allegedly died from overdoses.
In a memorandum opinion, signed by Circuit Judges John B. Owens, Mark J. Bennett, and Holly A. Thomas, the court said that District Court Judge Fernando L. Aenlle-Rocha of the Central District of California applied too high a threshold for relevance in excluding the evidence.
Challenging his conviction was Alexander Wilson, who was charged with violating 21 U.S.C. §841—which prohibits the distribution of fentanyl and proscribes increased penalties if the use of the drug results in death or serious bodily injury—relating to fatal overdose of Nathan Young-Nichols (referred to in the opinion as “N.Y.”) on May 15, 2020.
According to prosecutors, Young-Nichols purchased pills from Wilson on May 14 and was found dead the following morning in his bedroom. Investigators determined that his death was due to fentanyl poisoning.
Evidence was presented at trial that the defendant and the victim argued on Snapchat about the proper way to ingest the purported oxycodone, with Wilson telling the decedent not to chew the pills. Wilson allegedly shared screenshots of the conversation with his followers that night, mocking Young-Nichols.
Third-Party Liability
Before trial, the defendant submitted a trial brief to “update the Court on the status of the defense investigation regarding Jose Arambula, in support of the…request that the Court permit the defense to present its third-party liability case in full to the jury.” Prosecutors admit that Arambula and the decedent exchanged messages the night before the victim’s death, showing an attempted purchase of oxycodone, but say that the transaction was never completed
In the document, Wilson’s attorneys, Caleb Mason and Karen M. Sosa of the Los Angeles-based firm Werksman Jackson & Quinn LLP, wrote:
“The defense subpoenaed Snapchat for the names, phone numbers, and email addresses associated with each of the Snapchat usernames in Arambula’s contact list. Snapchat produced contact information for the approximately 2300 users. Of those, Snapchat had first and last names for 849 users….
“We cross-checked those 849 names against coroner’s records in Los Angeles and Orange Counties and have found fifty overdose deaths matching those names from 2018 through January 2023….[W]e cannot definitively rule out the possibility that some of these matches are actually two different people with the same name. However, there is a strong circumstantial inference that these matches are likely accurate; these are young people on the client list of a known pill dealer who admitted to and was caught selling adulterated pills laced with fentanyl, who later died of drug overdoses….
“Of those fifty overdose deaths, seven occurred between March and August, 2020…. Indeed, on the very day that N.Y. died (May 15, 2020), another young man on Arambula’s list died of a fentanyl overdose.”
Aenlle-Rocha excluded the evidence, along with testimony from law enforcement officers that they had purchased, in undercover operations, purported oxycodone pills from Arambula that turned out to be laced with fentanyl, saying the defendant failed to sufficiently “connect” Arambula to Young-Nichols’ death. After a jury found Wilson guilty, the judge sentenced him to 20 years in prison.
Relevant Evidence
The panel noted Federal Rule of Evidence 401 provides that “[e]vidence is relevant” if it has “any tendency to make a fact more or less probable than it would be without the evidence” and “is of consequence in determining the action.” Applying that standard, the judges wrote:
“The district court abused its discretion by excluding: 1) the testimonies of Special Agent Robert Thomas and Officer Robert Poindexter regarding Jose Arambula’s other drug dealings via Snapchat, including the Drug Enforcement Administration’s…undercover buys, 2) evidence of Arambula’s 2021 arrest and subsequent interview, 3) criminalist Julie Soltis’s testimony that Arambula sold counterfeit oxycodone containing fentanyl, and 4) evidence regarding the deaths of Arambula’s Snapchat contacts.”
They opined:
“First, the evidence tended to make the fact that a third party sold drugs to N.Y. more probable…as it shows someone else had the opportunity and ability to sell the drugs that killed N.Y….The evidence would have shown that a drug dealer, who sold counterfeit oxycodone laced with fentanyl…, messaged and called N.Y. before and after he died….Second, the excluded evidence was ‘of consequence in determining’ whether the drugs Wilson sold caused N.Y.’s death….The similarities between Arambula’s drug dealings and his interactions with N.Y. provide ‘an alternative theory of’ who gave N.Y. the fentanyl that killed him.”
Heightened Requirement
Saying that Aenlle-Rocha applied a “heightened relevancy requirement” not found in Rule 401, Owens, Bennett, and Thomas wrote:
“[T]he district court found Wilson could not ‘connect’ the third-party culpability evidence to N.Y.’s death, he did not have evidence that Arambula actually delivered drugs to N.Y. the night in question, and the evidence did not ‘prove’ Arambula ‘caused’ N.Y.’s death. But ‘third-party culpability evidence, to be admissible, need not be sufficient to sustain a guilty verdict against the third party.’….‘It need only have the potential, considered along with other evidence in the record, to raise a reasonable doubt as to the guilt of the defendant.’…By requiring Wilson to show something more than relevance, the district court abused its discretion.”
The jurists continued:
“[This evidence is especially probative here, where the government did not run tests on Wilson’s pills to determine whether they contained fentanyl instead of other drugs like MDMA, which was found in N.Y.’s toxicology report.”
Rejecting the government’s assertion that Aenlle-Rocha properly excluded the evidence under Rule 403, which specifies that “[t]he court may exclude relevant evidence if its probative value is substantially outweighed by a danger of…unfair prejudice, confusing the issues, [or] misleading the jury,” the judges said:
“To the extent the district court applied Rule 403, its application was erroneous because it did not appropriately weigh the relevance of the evidence.”
Especially Significant
Turning to the evidence that some of Arambula’s contacts may have died from overdoses, the judges reasoned:
“The death of one individual, S.H., is especially significant….Like N.Y., S.H. communicated with Arambula via Snapchat about purchasing oxycodone and died a week after that communication. S.H.’s case was an example of another minor who overdosed from the same drug as N.Y. (fentanyl), in the same region, after communicating with the same drug dealer (Arambula), requesting to purchase the same drug (“Oxy”), through the same social media platform (Snapchat). Yet the district court…excluded the evidence under Rule 403 on grounds that it was ‘highly speculative’ and ‘unduly prejudicial.’ This was erroneous.”
Finding prejudice in the exclusion, they wrote:
“The excluded evidence went to the heart of Wilson’s defense—that someone else had the opportunity and ability to sell the drugs that killed N.Y. The length of the jury deliberations and the fact that the jury could not reach a verdict until after two jurors were discharged and replaced with alternates also weigh against a finding of harmlessness.”
Ownes, Bennett, and Thomas reversed the judgment of conviction and remanded the matter for retrial.
The case is U.S. v. Wilson, 23-3956.
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