United States v. Jose Gonzalez, Roberto Gonzalez, Jorge Luis Fonte, Manual Rodriguez A/K/A Manny

Defendant-appellants were convicted on many narcotics violations and Racketeer Influenced and Corrupt Organizations (RICO) conspiracy in violation of 18 U.S.C. § 1962(d). 1 They allege several errors occurred at trial. Only two deserve discussion. 2 In this ease we consider whether, under Florida law, police use of handcuffs on a victim while committing a larceny makes the act a robbery for purposes of 18 U.S.C. § 1961(1)(A). We also decide whether the heightened evidentiary requirements imposed on the use of “net worth” or “cash expenditure analysis” evidence in tax evasion cases apply when…