Summary
The Sixth Circuit Court of Appeals reviewed the criminal conviction of a dentist charged with illegally prescribing controlled substances that resulted in a patient's death. While the court found sufficient evidence to support the conviction, it held that the district court improperly admitted testimony regarding the defendant's prior bad acts as intrinsic evidence, violating Federal Rule of Evidence 404(b). Consequently, the appellate court vacated the convictions and remanded the case for a new trial.
Topics
Practice areas
Questions Presented
- Whether the evidence was sufficient to support Sadrinia's convictions under 21 U.S.C. § 841.
- Whether the district court erred in admitting prior‑bad‑act testimony as intrinsic evidence in violation of Fed. R. Evid. 404(b).
- Whether the jury instructions and verdict form constituted a constructive amendment of the indictment in violation of the Fifth Amendment.
Holdings
- Sufficient evidence supported Sadrinia’s conviction.
- The district court abused its discretion by admitting the testimony as intrinsic; the convictions are vacated and the case remanded for a new trial.
- The instructions did not constitute a constitutional error; the indictment’s conjunctive language may be proved in the disjunctive.
Key quotations
“We hold that sufficient evidence supported Sadrinia’s conviction. But we agree with him that the district court improperly admitted—as “intrinsic evidence” of the conduct charged in the indictment— testimony about bad acts unrelated to that conduct.” (at 1)
Factual background
Dentist Jay Sadrinia prescribed large quantities of morphine and other opioids to patient Cheyenne Witt, who later died from an overdose. The government alleged that the prescriptions lacked a legitimate medical purpose and that Sadrinia knowingly distributed controlled substances illegally. The trial included testimony about Sadrinia's prior bad acts, which the district court admitted as "intrinsic" evidence.
Procedural history
The district court convicted Sadrinia of illegal distribution of controlled substances and of causing Witt's death, denied his post‑trial motions, and sentenced him to 240 months. The Sixth Circuit reviewed the sufficiency of the evidence, the admission of prior‑bad‑act testimony under Rule 404(b), and the jury instructions.
Remand instructions
Remand for a new trial.