201702P.pdf   07/29/2021  United States  v.  Jose Ramirez-Martinez
   U.S. Court of Appeals Case No:  20-1702
   U.S. District Court for the Northern District of Iowa - Western   
   [PUBLISHED] [Shepherd, Author, with Erickson and Kobes, Circuit Judges] 
   Criminal case - Criminal law. The district court did not abuse its 
   discretion by admitting text messages and transcripts of phone calls 
   between defendant and his co-defendants; the government properly 
   authenticated the text messages, providing sufficient evidence to support 
   a finding that the messages sent and received from a particular number 
   were sent and received by defendant; the district court properly admitted 
   texts between the co-conspirators in furtherance of the conspiracy and 
   even if admission of the texts was erroneous, the evidence in the texts 
   was corroborated by overwhelming evidence of defendant's participation in 
   the conspiracy; the evidence was sufficient to support defendant's 
   conviction for conspiracy to distribute methamphetamine.