9th Circuit upholds drug distribution and money laundering conviction, finding no reversible error in jury…
United States v. Sangbarani
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9th Circuit upholds drug distribution and money laundering conviction, finding no reversible error in jury instructions, evidentiary rulings, or witness impeachment limits.
Why it matters
The Ninth Circuit affirmed Arbi Setaghaian Sangbarani's conviction on drug distribution and money laundering charges, rejecting all six of his arguments on appeal. The court found that any errors in jury instructions were harmless because the jury had already received substantial information about cooperating witnesses and their agreements with the government. Evidentiary rulings limiting certain impeachment evidence and excluding a defense paralegal's summary chart were upheld as proper exercises of the trial court's discretion.
Who it affects
- This ruling directly affects Sangbarani
- Whose conviction
- Sentence stand. More broadly
- Which is relevant to criminal defendants
- Defense attorneys in the Ninth Circuit
What happens next
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Decision issued Jul 13, 2026
Unpublished opinion
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- Decision issued Jul 13, 2026Unpublished opinion
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Jul 13, 2026 · Unpublished opinion
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Sangbarani was convicted by a jury on multiple counts of drug distribution and money laundering in the Central District of California. He appealed, raising six distinct challenges to how his trial was conducted, including complaints about jury instructions, limits on cross-examination, excluded defense evidence, admitted Bitcoin evidence, and a deliberate ignorance instruction. On jury instructions, Sangbarani argued the court should have told jurors that cooperating witnesses received benefits from the government in exchange for testimony, and separately that the court should have given a 'mere presence' instruction clarifying that simply being present at a crime does not make someone guilty. The appeals court found any error on the benefits instruction was harmless because the jury already heard that both cooperating witnesses pleaded guilty and testified under cooperation agreements, and defense counsel highlighted this in closing argument. The 'mere presence' instruction was not required because the government's case rested on more than just Sangbarani's presence. On cross-examination and evidence, Sangbarani argued he was unconstitutionally barred from impeaching a cooperating witness with fraud convictions older than ten years and an uncharged burglary. The court disagreed, noting the witness had already been thoroughly impeached through cross-examination on other crimes involving fraud and false representations, making the additional impeachment material unnecessary. The court also upheld limits on testimony by a defense paralegal and exclusion of a summary chart she prepared, finding the chart's information was largely irrelevant given that the jury had already seen videos and heard the paralegal's other testimony about what those videos showed. The court also upheld admission of Bitcoin deposit evidence, finding cooperating witnesses had provided sufficient foundation by testifying about the financial structure of the conspiracy and Sangbarani's role in it. Finally, the court found no reversible error in the deliberate ignorance jury instruction, including a one-word misstatement made orally by the judge, because the jury received the correct written version of the instruction. Judge Friedland wrote a separate concurrence, though its content is not detailed in the available text. This is a non-precedential memorandum disposition, meaning it does not create binding legal precedent for future cases.
CITATION AND RECORD
Record source: CourtListener
NOT FOR PUBLICATION FILED UNITED STATES COURT OF APPEALS JUL 13 2026 MOLLY C. DWYER, CLERK U.S. COURT OF APPEALS FOR THE NINTH CIRCUIT UNITED STATES OF AMERICA, No. 24-3339 D.C. No. Plaintiff - Appellee, 2:22-cr-00360-AB v. MEMORANDUM* ARBI SETAGHAIAN SANGBARANI, Defendant - Appellant. Appeal from the United States District Court for the Central District of California André Birotte, Jr., District Judge, Presiding Argued and Submitted April 21, 2026 Pasadena, California Before: FRIEDLAND and MILLER, Circuit Judges, and VITALIANO, District Judge.** Concurrence by Judge Friedland. Defendant-Appellant Arbi Setaghaian Sangbarani appeals his conviction by a jury on several counts of drug distribution and money laundering. We have jurisdiction under 28 U.S.C. § 1291, and we affirm. * This disposition is not appropriate for publication and is not precedent except as provided by Ninth Circuit Rule 36-3. ** The Honorable Eric N. Vitaliano, United States District Judge for the Eastern District of New York, sitting by designation. We review the district court’s formulation of jury instructions for abuse of discretion. United States v. Cortes, 757 F.3d 850, 857 (9th Cir. 2014). The parties dispute whether we should review de novo because Defendant contends that the failure to give a requested instruction prevented him from presenting his theory of the case. Id. Because Defendant’s arguments fail under either standard, we assume without deciding that de novo review applies to his jury instruction arguments. We review for abuse of discretion challenges to the district court’s evidentiary rulings. United States v. Sutcliffe, 505 F.3d 944, 958 (9th Cir. 2007). We review de novo whether an evidentiary ruling rises to the level of a constitutional violation. United States v. Pineda-Doval, 614 F.3d 1019, 1032 (9th Cir. 2010). We review claims of a constructive amendment de novo. United States v. Hartz, 458 F.3d 1011, 1019 (9th Cir. 2006). 1. Defendant argues that the district court erred by refusing to instruct the jury that two cooperating witnesses had “received benefits” from the Government in exchange for their testimony against Defendant. Even assuming that was error, it was harmless because “there is no reasonable possibility that the error materially affected the verdict.” United States v. Pierre, 254 F.3d 872, 877 (9th Cir. 2001) (citation omitted). The district court gave a “greater caution” instruction about both cooperating witnesses, the jury heard evidence that both witnesses pleaded guilty to participating in the alleged conspiracy, and that they were testifying under 2 24-3339 cooperation agreements, a point that defense counsel emphasized in closing argument. The principal cooperating witness was also thoroughly impeached with his extensive criminal history, including convictions related to fraud and drugs. 2. Defendant contends that the district court erred by declining to allow him to impeach a cooperating witness with fraud convictions more than 10 years old and an uncharged burglary, and that preventing him from doing so violated his Confrontation Clause rights. Given that the witness’s credibility had already been thoroughly impeached through cross-examination on other arrests, charges, and crimes involving false or fraudulent representations, barring the use of the stale convictions and uncharged conduct to impeach him was neither an abuse of discretion nor a denial of Defendant’s right to conduct an effective cross- examination under the Confrontation Clause. See Simpson v. Thomas, 528 F.3d 685, 690 (9th Cir. 2008) (explaining that convictions more than 10 years old are admitted “very rarely[,] and only in exceptional circumstances”); United States v. Glenn, 667 F.2d 1269, 1273 (9th Cir. 1982) (barring the admission of burglary convictions on the basis that they did not involve fraud or deceit). 3. Defendant argues that the district court erred by failing to give a “mere presence” instruction under Model Instruction 5.12 because the omission prevented him from adequately presenting his defense. But where, as here, the 3 24-3339 “government’s case is based on more than just a defendant’s presence, and the jury is properly instructed on all elements of the crime,” the trial court is not required to give the jury the “mere presence” instruction. United States v. Negrete-Gonzales, 966 F.2d 1277, 1282 (9th Cir. 1992). 4. Defendant contends that the district court erred by disallowing lay testimony by a defense paralegal, and by precluding the admission of a summary chart that she prepared. Neither evidentiary ruling was an abuse of discretion. Defendant was permitted to show the jury videos showing that, unlike the other acknowledged co-conspirators, Defendant wore no gloves and did not engage in any of the packaging or mailing activities. The paralegal was also permitted to testify that there were no videos in which Defendant either wore gloves or carried packages containing drugs. The information contained in the summary chart was largely irrelevant and would have added little probative information beyond what the jury obtained through the videos and paralegal testimony, so excluding the chart was appropriate. See Fed. R. Evid. 403; Fed. R. Evid. 1006. Similarly, “[t]he admissibility of lay opinion testimony under Rule 701 is committed to the sound discretion of the trial judge and his decision will be overturned only if it constitutes a clear abuse of discretion,” and there was no such clear abuse here in excluding further testimony by the paralegal. United States v. Gadson, 763 F.3d 1189, 1209 (9th Cir. 2014) (citation omitted). 4 24-3339 5. Defendant argues that the district court abused its discretion by admitting evidence of certain Bitcoin deposits into his cryptocurrency account. But sufficient foundation was laid for the admission of these deposits given the testimony of the cooperating witnesses about the financial structure of the conspiracy and Defendant’s role in that structure. 6. Defendant contends that the district court erred by giving Model Jury Instruction 4.9 on “deliberate ignorance,” and by misstating that instruction. The district court did not abuse its discretion in giving the instruction because the jury could have rationally found that Defendant was aware that there was a high probability that the proceeds he received were the fruits of the crime and willfully blinded himself by deliberately avoiding learning the truth. United States v. Heredia, 483 F.3d 913, 922 (9th Cir. 2007) (en banc). The Government was permitted to argue actual knowledge and deliberate ignorance in the alternative. United States v. Ramos-Atondo, 732 F.3d 1113, 1120 (9th Cir. 2013). The district court’s misstatement of one word of the “deliberate indifference” instruction, when the jury received the correct version of those instructions on paper, did not prejudice Defendant, so it was nothing more than harmless error. See United States v. Conti, 804 F.3d 977, 9
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