Case Explained: USA V. SMITH

Court: United States Court of Appeals for the Ninth Circuit Filed: 2026-08-17 Docket: 3:23-cr-00017-SLG-KFR-1 The Ninth Circuit affirmed the convictions of Cornelius Leon William Smith for dealing firearms without a license, transferring a firearm to an out-of-state resident, and making false statements during firearm purchases. The court held that the district court did not abuse its discretion in admitting evidence regarding the criminal history and conduct of Smith’s cousin, Andrew Williams, finding it relevant to prove Smith’s knowledge that he was selling firearms to individuals who could not lawfully possess them, and determining that the probative value of this limited testimony was not substantially outweighed by unfair prejudice under Federal Rule of Evidence 403. Additionally, the court rejected Smith’s challenge to the admission of two photographic exhibits (Exhibits 11 and 31) depicting recovered firearms, ruling that they were admissible to prove the recovery of the weapons and did not conflict with other evidentiary rulings regarding firearm modifications. Regarding the denial of a mistrial motion, the court applied the standard from *United States v. Lemus*, concluding that the district court’s curative instruction to disregard an agent’s irrelevant testimony about drug residue on a scale was sufficient to cure any prejudice, particularly given the jury’s acquittal on one count and the strong presumption that jurors follow such instructions. Consequently, Smith’s convictions stand and he remains subject to the sentence imposed by the district court. Do It For The Case Law is a news reporting service. Nothing in this episode constitutes legal advice.