Admissible Evidence-Hearsay

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7^th Circuit Court of Appeals

Case Name: United States of America v. Elvis Medrano

Case No.: 22-3219

Officials: Brennan, St. Eve, and Jackson -Akiwumi, Circuit Judges.

Focus: Admissible Evidence-Hearsay

A supplier shipped substances containing detectable amounts of methamphetamine, cocaine, and MDMA from California to Indiana. In Indiana, Medrano and his associates used the U.S. Post Office and a post office employee to distribute these drugs. Law enforcement officers traced Medrano to a motel in Indiana and attempted to apprehend him. However, Medrano managed to escape and initiated a high-speed chase with officers. Although he initially evaded arrest, officers recovered his truck and took one of his co-conspirators into custody.

Subsequently, law enforcement secured a warrant to search Medrano’s motel room, where they discovered various incriminating items, including a burner phone, drug paraphernalia such as scales and baggies, substances used to dilute methamphetamine, and a key to a post office box, which Medrano had received from a post office employee. Officers later tracked Medrano to another motel, where he once again led them on a high-speed chase and eluded capture.

Officers eventually executed a search warrant for Medrano’s motel room and found additional drug paraphernalia, along with another phone belonging to Medrano. Finally, Medrano was apprehended at a residence in Indiana, where law enforcement discovered methamphetamine, more paraphernalia, and a third phone containing text messages exchanged between Medrano and an individual referred to as “Rob Marshalltown.” These text messages were later presented as evidence during the trial.

The Seventh Circuit upheld Medrano’s conviction under 21 U.S.C. 841(a)(1) and 846, noting that any potential error in admitting the text messages was inconsequential when considering the entirety of the evidence presented at the trial.

Affirmed.

Decided 10/16/23

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