context: Based on our recent precedents, admission of those statements as lay opinion testimony was error. However, the District Court later qualified Agent Sparks as an expert in the investigation of drug trafficking based on his "training and experience on hundreds of investigations." Aug. 13, 2001 Trial Tr. at 17649. Because Agent Sparks would have qualified as an expert for purposes of the challenged testimony, there was no prejudice from that particular error.
citation_a.signal: see also
citation_a.identifier: 640 F.3d 358, 366
citation_a.parenthetical: agent's improper lay testimony was harmless error where agent would have qualified as an expert
citation_a.sentence: See Moore, 651 F.3d at 61 (that Agent Sparks “might have qualified as an expert” ameliorated prejudice from improper opinion testimony); see also United States v. Smith, 640 F.3d 358, 366 (D.C.Cir.2011) (agent’s improper lay testimony was harmless error where agent would have qualified as an expert).
citation_b.signal: see
citation_b.identifier: 651 F.3d 61, 61
citation_b.parenthetical: that Agent Sparks "might have qualified as an expert" ameliorated prejudice from improper opinion testimony
citation_b.sentence: See Moore, 651 F.3d at 61 (that Agent Sparks “might have qualified as an expert” ameliorated prejudice from improper opinion testimony); see also United States v. Smith, 640 F.3d 358, 366 (D.C.Cir.2011) (agent’s improper lay testimony was harmless error where agent would have qualified as an expert).