United States v. Salvador Ahumada-Avalos

Defendant-appellant Salvador Ahumada-Avalos was convicted and sentenced to ten years in prison in the Eastern District of Washington for participating in the sale and distribution of over 500 grams of cocaine. The sale was consummated in Idaho. The government obtained evidence identifying Ahumada-Avalos and linking him to Qriminal conduct by subpoenaing telephone company records of toll calls made from an unlisted telephone number.

Ahumada-Avalos contends that the district court erred (1) in not instructing the jury that in a multi-district conspiracy case, an overt act must occur in the…