Seventh Circuit -- USA v. James Green

USA v. James Green

 No Bruton violation in co-deft's reference to a "straw buyer" when deft had been clearly identified as a straw buyer earlier in the trial.  There might have been many, so the reference was insufficiently obvious.

No error in giving the sophisticated scheme sentencing bump where the scheme was sophisticated and the deft possibly less so.

No error in court's holding that there was one big conspiracy as opposed to several smaller ones.

Possible error in admission of evidence under 902(11) (Records in course of business) was harmless.

No error in gov't's repeated citation to an uncharged parallel offense.

No error in ostrich instruction (deliberate avoidance of knowledge)

Public auctions not a reliable means of calculating the damages, as not a reliable indication of true price.