United States v. Ayala-Pizarro

After arresting Ayala-Pizarro (defendant) outside a known drug house with 153 foil packets of heroin, Officer Mulero testified at trial about how drug points typically operate and that heroin at such locations was commonly packaged in aluminum foil, based on his personal experience with that specific house and with drug points generally; Ayala objected that this was undisclosed expert testimony, but the trial court permitted it as lay testimony, and Ayala was convicted and appealed.