Third Circuit Upholds Trial Court's Admission of Testimony on Modus Operandi of Drug Dealers over Relevance Objection

In an unpublished opinion, the Third Circuit has upheld the trial court's admission of expert testimony from a law enforcement officer on the modus operandi of drug trafficking organizations. From the opinion:

[Defendant] does not challenge Agent Bellis' qualifications to testify, but argues instead that Bellis' testimony about shootings and the use of firearms in drug conspiracies did not "assist the trier of fact" under Rule 702, and was in fact prejudicial because there was no evidence connecting Reynolds to any firearms or violence. We reject this claim. Bellis' statements about firearms and shootings were not central to his testimony, and in the context of a general discussion of the operation of drug organizations, they did not prejudice [defendant's] case. The District Court reasonably concluded that Agent Bellis' testimony would assist the jury in understanding the nature of the conspiracy alleged by the government. Thus, we hold that the District Court did not abuse its discretion in permitting the testimony of Agent Bellis.

See United States v. Reynolds, No. 04-3183 (3d Cir. Mar. 27, 2006) (Sloviter, Fuentes, & Restani, JJ.).