US v. Lucio Garcia — 4th Cir. (Sep 15, 2026)
Lucio Garcia is appealing a firearm conviction from a federal drug-trafficking trial in eastern North Carolina. Officers searching his home found drugs and a loaded firearm, and a jury convicted him of drug offenses and possessing the gun to advance drug trafficking. At trial, an expert testified that the firearm was possessed in furtherance of drug trafficking. The appeal asks whether that opinion improperly decided Garcia's intent for the jury. Rule seven-oh-four, subsection B, prohibits an expert from stating whether a criminal defendant had the mental state required for the offense or a defense. In Diaz, the Supreme Court allowed testimony about what most drug couriers know, leaving the particular defendant's knowledge for the jury to decide. A curative instruction is a judge's direction meant to correct how jurors use testimony. Harmless error is a mistake that does not affect substantial rights and therefore does not require reversing a conviction.
US v. Lucio Garcia (No. 25-4023) — U.S. Court of Appeals for the Fourth Circuit, argued September 15, 2026.
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