In US v. Garcia, No. 09-40575, the court of appeals affirmed defendant's cocaine possession conviction, on the grounds of 1) defendant did not qualify his consent to the police, who therefore had general consent to search defendant's truck; and 2) when the officers requested permission to search the truck after asking defendant whether he was carrying "anything illegal," it was natural to conclude that they might look for hidden compartments or containers. However, the court remanded defendant's sentence for correction of a clerical error in the judgment.
In US v. Santillana, No. 09-50298, the Fifth Circuit affirmed defendant's conviction for distributing methadone resulting in another's death, on the grounds that 1) although the evidence did not provide an airtight chain-of-custody account of the methadone tablets defendant sold to the victim, there was ample support for a reasonable jury to infer that the victim ingested those tablets before slipping into his fatal coma; and 2) there was sufficient evidence for a reasonable jury to conclude that the victim's death resulted from his use of methadone under a heightened standard of causation.