Does a potential defect in a drug trafficking-trafficking predicate in a criminal conviction apply to a crime of violence?

MultiRegion, United States of America

The following excerpt is from United States v. Vasquez, No. 14-2494-cr(L), No. 14-3630-cr(Con) (2nd Cir. 2016):

drug-trafficking predicate, no Yates concern arises from a possible defect in a related "crime of violence" predicate. See United States v. Zvi, 168 F.3d 49, 55-56 (2d Cir. 1999) (rejecting Yates challenge where time-barred money-laundering predicate implicitly required finding of valid wire-fraud predicate); see also United States v. Coppola, 671 F.3d 220, 237-38 (2d Cir. 2012) (holding any Yates error harmless where predicates rested on same extortive acts of which jury found defendants guilty).

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