United States v. Montas
United States Court of Appeals for the First Circuit
41 F.3d 775 (1st Cir. 1994)
Hector Julio Felix Montas (defendant) was charged with possessing cocaine with intent to distribute after a customs K-9 unit detected cocaine hidden in his luggage, which bore a name different from his own. At trial, DEA agent Ivan Rios testified, over Montas's objections for speculation, relevance, and leading questions, that drug smugglers generally avoid using their real names on tickets and luggage. Montas was convicted and appealed, arguing Rios's testimony was improper expert testimony on a subject within an average juror's own understanding, though he had not specifically objected on that expert-testimony ground at trial.
Whether expert testimony may be used if an untrained layman would be able to understand the issue without an explanation from someone with specialized understanding of the subject.