Defendant's drug conviction and sentence are affirmed where: 1) sufficient evidence independent of hearsay statements showed that defendant was a member of the drug conspiracy at issue; and 2) any potential error caused by trying multiple conspiracies under a single indictment did not influence the fairness of the trial.
Argued: April 23, 2009
Decided and Filed: August 18, 2009
Opinion by Judge Cole
Paul L. Nelson, Federal Public Defender's Office, Western District of Michigan, Grand Rapids, MI
Ava M.R. Dustin, Assistant United States Attorney, Toledo, OH