191025P.pdf   07/07/2020  United States  v.  Jose Andres Vera-Gutierrez
   U.S. Court of Appeals Case No:  19-1025
   U.S. District Court for the District of Minnesota   
   [PUBLISHED] [Benton, Author, with Loken and Kelly, Circuit Judges] 
   Criminal case - Criminal law and sentencing. The trial record showed 
   numerous phone contacts between defendant and his co-conspirators and even 
   if the admission of an exhibit charting the contacts was erroneous for 
   lack of a proper foundation, the error was harmless; similarly, the other 
   items defendant challenges also duplicate other evidence and testimony, 
   and any error in their admission was harmless; no error in imposing an 
   enhancement for obstruction of justice under Guidelines Sec. 3C1.1 based 
   on defendant's threats to a witness prior to trial; within-guidelines 
   range was not substantively unreasonable, and the district court did not 
   abuse its discretion in denying defendant's request for a downward 
   variance.