United States v. Rodriguez-Felix

TYMKOVICH, Circuit Judge.

Juan Rodriguez-Felix claims he is the victim of mistaken identification at his trial for distributing cocaine base in violation of 21 U.S.C. §§ 841(a)(1) and (b)(1)(B). He was convicted based in large part on extensive trial testimony from multiple eyewitnesses. To dispute this evidence, Rodriguez-Felix sought to introduce expert testimony on the general reliability of the prosecution’s eyewitnesses. The district court disallowed the proposed expert testimony, finding it to be unreliable, and consequently limited rebuttal of the eyewitness testimony solely to…