United States v. Serrano

Roberto Serrano (defendant) was convicted of aiding and abetting the distribution of cocaine. Serrano was arrested after an undercover officer went to a residence at 4506 Spatz Avenue in Fort Wayne, Indiana, and attempted to buy one-and-a-half kilograms of cocaine. During the transaction, the officer asked where the rest of the cocaine was, and Serrano told him where it was. Following Serrano’s arrest, officers found a driver’s license with Serrano’s picture, the name Eddie Roncone, and the 4506 Spatz Avenue address. The officers found a state ID card with Serrano’s picture, the name Eddie Roncone, but an address on Evans Street in Fort Wayne. The officers found in the basement other evidence of a cocaine enterprise being conducted at the residence. Before the cocaine transaction occurred, a search of the trash outside of 4506 Spatz Avenue turned up automobile-insurance cards, insurance declarations, and related correspondence bearing the name Eddie Roncone and the Spatz Avenue address. Serrano objected to the admission of the driver’s license, ID card, and insurance documents on the grounds that they were hearsay. The trial court overruled and admitted the documents. During the trial, Serrano’s only defense was that because he did not live at the Spatz Avenue address, he could not have been involved in the cocaine enterprise being conducted there other than to help point out the location of some of the cocaine the undercover officer was trying to buy. Following his conviction, Serrano appealed the court’s admission of the documents with the Spatz Avenue address.