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United States v. Trent

United States Court of Appeals, Seventh Circuit

July 13, 2017

United States of America, Plaintiff-Appellee,
Phil Lamont Trent, Defendant-Appellant.

          Argued May 19, 2017

         Appeal from the United States District Court for the Central District of Illinois. No. 4:15-cr-40026-001 - Sara Darrow, Judge.

          Before WOOD, Chief Judge, and POSNER and Kanne, Circuit Judges.

          Kanne, Circuit Judge.

         Defendant-Appellant Phil Trent distributed heroin that killed Tyler Corzette. He was charged in a five-count indictment, which included two counts related to Corzette's death.

         At trial, Trent objected to testimony of two of the government's witnesses: Kyle Hull and Curtis Land. Like Trent, these witnesses had also been charged with distribution of heroin resulting in Corzette's death, but each pled guilty to that charge pursuant to a plea agreement.

         Trent sought to impeach Hull and Land based on their plea agreements. Specifically, he wanted to question them about the twenty-year mandatory minimum associated with the heroin-distribution-resulting-in-death charges. But because Trent had also been charged with distribution resulting in Corzette's death, he faced the same twenty-year mandatory minimum if convicted.

         The district court noted that, if the jury became aware of the exact length of Hull's and Land's mandatory minimum, it would also know the minimum penalty that Trent would have to serve-which could improperly sway the jury's decision in Trent's case. To avoid this situation, the court prevented Trent from asking Hull and Land about the mandatory minimum's exact length but permitted him to describe the mandatory minimum as "substantial."

         Trent now argues that this limitation violated his Sixth Amendment right to confrontation and was an abuse of discretion. We disagree and hold that the court committed no error in its ruling.

         Trent also objected to the testimony of Illinois State Police Sergeant James Rieck, a government witness who had investigated Trent while undercover. During that investigation, Sergeant Rieck had communicated with Trent in person and by telephone. At trial, Sergeant Rieck identified Trent's voice in the phone calls. Trent objected to this identification, claiming that the government had not laid the necessary foundation. He asserts that argument again on appeal. We disagree and hold that the court also did not err in allowing that testimony.

         I. Background

         Trent was a heroin supplier in Rock Island, Illinois. Hull was a heroin addict who often purchased heroin from Trent and his dealers. On August 29, 2014, Hull planned to attend a local music festival with one of his friends, Corzette, who was also a heroin addict. The two decided to purchase heroin before they went to the festival. Hull called Trent and ordered three "bags" of heroin (each of which contained a tenth of a gram), one bag for Corzette and two bags for another friend, Jacob Thompson. Hull did not order any heroin for himself because he was already high from using heroin earlier that day-heroin that he had also purchased from Trent. Trent set the price at $90 for the three bags and told Hull to contact Land, one of Trent's dealers.

         Hull then called Land, and they arranged a meeting. Hull, Corzette, and Thompson rode together to that meeting, and once they arrived, Hull purchased the bags of heroin from Land for the agreed-upon price. After the deal, Thompson took his two bags of heroin and went home.

         Hull and Corzette then went to a nearby park where Hull helped Corzette cook and inject the heroin. Soon thereafter, Corzette passed out. Hull, who later testified that he was not initially worried about Corzette because he had seen this happen before with heroin use, left Corzette in the car and attended the music festival.

         After the festival, Hull returned to the car and found Corzette still unconscious and with vomit on his clothes. Hull checked Corzette's pulse and, still believing him to be fine, left Corzette in the car for the night. When Hull returned the following morning, he found Corzette dead in the car.

         Hull panicked. He took the syringe from Corzette's hand and threw it in the grass next to the car. He then went to work. But after spending only an hour at work, Hull returned to the park and called the police. Rock Island Police Officer Christopher Sloan responded to the call. When he arrived, he spoke with Hull, who claimed that Corzette was dead. Officer Sloan called an ambulance and confirmed that Corzette was in fact dead. He then discovered the syringe that Hull had thrown in the grass. A forensic pathologist later concluded that Corzette had died of adverse effects from heroin.

         A. Investigation and Arrest of Trent

         Later on August 30, Hull agreed to cooperate with the police department in its investigation. In particular, Hull agreed to participate in a controlled purchase of three additional bags of heroin from Land that same day. This controlled purchase led to Land's arrest, after which Land also agreed to cooperate. The police department then arranged for an undercover officer to make two purchases of heroin from Trent. After the second purchase, the police department obtained an arrest warrant for Trent, and Trent was arrested on October 3, 2014.

         The Rock Island Police Department later learned that the Illinois State Police had also been engaged in an undercover investigation of Trent in August of 2014. During that investigation, Sergeant Rieck communicated with Trent both in person and by telephone. He also purchased $50 of heroin from one of Trent's dealers. Sergeant Rieck attempted to arrange a second purchase of heroin from Trent, but Trent refused after discovering that Rieck was an undercover officer.

         B. Trent's Jury Trial

         A grand jury returned a five-count indictment, charging Trent with one count of heroin distribution resulting in death, three counts of heroin distribution, and one count of conspiracy to distribute and possess with intent to distribute heroin resulting in death. These charges stemmed from both the Rock Island Police Department's investigation and the Illinois State Police's investigation of Trent. ...

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