United States v. Galitsa

Summary

Defendant convicted of illegal reentry and false statements challenged evidentiary rulings admitting prior acts, charges, and convictions, and the language used in cross-examination. The Second Circuit affirmed, holding that even if the district court erred in admitting certain evidence, any error was harmless given the overwhelming evidence of guilt, including testimony, records, and bank data confirming removal. The court also found that a curative instruction cured any prejudice from an inadvertent reference to prior arrests, as juries are presumed to follow limiting instructions.

Holdings

1. Any purported evidentiary errors were harmless because the government presented overwhelming evidence of guilt, and the challenged evidence was cumulative of other impeachment evidence.

Questions Presented

1. Whether the district court erred in admitting evidence of Galitsa's prior arrests, charges, and convictions
2. Whether the district court erred in allowing cross-examination about those incidents

Disposition

affirmed