United States v. Brown
United States Court of Appeals for the Eleventh Circuit
299 F.3d 1252 (11th Cir. 1999)
Authorities found cocaine base in Jacqueline Brown's (defendant's) luggage during an airport search en route to Bermuda; she claimed no knowledge of the drugs, and to counter this defense, the prosecution introduced testimony from a DEA agent, qualified as a drug-valuation expert, that the cocaine was worth $217,000 in Bermuda — testimony intended to show someone unaware of possessing such valuable contraband would not have been trusted by its owners to transport it. The agent based his valuation partly on information obtained from another DEA agent who had queried Bermudan authorities, and the trial court admitted this testimony and convicted Brown, who appealed on hearsay grounds.
Whether an expert witness's drug-valuation testimony may properly rely on hearsay information obtained through another law enforcement agent's inquiry to foreign authorities.