United States v. Michael Lee Bolick

MURNAGHAN, Circuit Judge:

Michael Bolick has appealed his conviction for conspiring to sell, and selling, cocaine. Bolick’s primary contention is that the trial court impermissibly admitted prior consistent statements of government witnesses who had not yet been impeached. He also contends that the trial court impermissibly allowed the government to create a prejudicial “drug atmosphere” at trial under the guise of “background” evidence.

I

In early September 1987, undercover government agent D.C. Ramsey arranged to purchase an ounce of cocaine from Ray Samuel Dicks. Agent Ramsey had established…