United States v. Natal

In this appeal of judgments of conviction and sentence involving crimes that include arson resulting in death, accessory after the fact to arson, and destruction and concealment of evidence, we write to address three issues:(1) Whether testimony on how cell phone towers operate must be provided by an expert witness rather than a lay witness;(2) Whether defendant Morales’s conviction for destruction and concealment of evidence for re-painting his van must be vacated in light of the Supreme Court’s holding in an intervening decision, Yates v. United States, — U.S. -, 135 S.Ct. 1074, 191 L.Ed.2d…