United States v. Omari Andrews, Jr.

── United States v. Omari Andrews, Jr. ── Court: Court of Appeals for the Seventh Circuit Date: April 15, 2026 Category: General In the United States Court of Appeals For the Seventh Circuit ____________________ No. 25-1904 UNITED STATES OF AMERICA, Plaintiff-Appellee, v. OMARI ANDREWS, JR., Defendant-Appellant. ____________________ Appeal from the United States District Court for the Northern District of Illinois, Eastern Division. No. 23-cr-00170 — Edmond E. Chang, Judge. ____________________ ARGUED FEBRUARY 26, 2026 — DECIDED APRIL 15, 2026 ____________________ Before EASTERBROOK, SCUDDER, and ST. EVE, Circuit Judges. ST. EVE, Circuit Judge. A jury convicted Omari Andrews, Jr., of possessing four firearms in furtherance of a drug trafficking crime. Andrews challenges the sufficiency of the evidence for his firearm conviction and the admission of certain expert tes- timony. The district court rejected both arguments when it de- nied Andrews’s post-trial motions. We affirm. 2 No. 25-1904 I. Background A joint federal and local law enforcement investigation suspected that Omari Andrews, Jr., supplied drugs to a gang in Skokie and Evanston, Illinois. On five occasions, law en- forcement conducted controlled buys of cocaine, heroin, and fentanyl from Andrews. Officers then obtained a warrant for Andrews’s arrest, and a search warrant for an apartment in Mount Prospect, Illinois (the “Palm Drive apartment”). An- drews jointly occupied the Palm Drive apartment with his mother, who leased it, his younger brother, and other family. In March 2023, law enforcement arrested Andrews. Dur- ing the arrest, officers found nine small plastic bags contain- ing heroin, fentanyl, cocaine, and a cocaine base in Andrews’s pockets. Officers then searched the Palm Drive apartment, where they found more drugs and items associated with drug production and trafficking. They also found four firearms: (i) a Glock 19, (ii) a Glock 27, (iii) a Glock 19X, and (iv) an AR- style pistol. While in custody, Andrews called his parents on a rec- orded jail phone. During the conversation, Andrews asked his parents, “you think they gonna hit me with a 922(c),” to which his father responded, “how many you had in [the] house?” Andrews replied, “[t]here was four … they wasn’t together like one, you know what I’m saying? They was [in] different rooms.” A grand jury indicted Andrews on seven counts. Counts one through five charged him with distribution of a con- trolled substance, 21 U.S.C. § 841(a)(1), reflecting the five con- trolled buys. Count six charged him with possession with in- tent to distribute a controlled substance, § 841(a)(1), reflecting No. 25-1904 3 the drugs found in Andrews’s pockets. Count seven charged him with possession of a firearm in furtherance of a drug traf- ficking crime, 18 U.S.C. § 924(c)(1)(A), listing the four firearms in the apartment. Andrews eventually pleaded guilty to the first five counts and proceeded to trial on counts six and seven. During pretrial discovery, the government disclosed that its fingerprint analyst, Thomas Kern, analyzed fingerprints on the Glock 27 and the AR-style pistol (latent prints 3A and 4A, respectively) and matched both to Andrews’s known finger- prints. In early July 2024, over a month before trial, the gov- ernment confirmed it intended to call Kern as an expert at trial and disclosed Kern’s qualifications, opinions, and the bases for those opinions. Andrews did not disclose whether he planned to call an expert witness by either the July 15 witness list deadline or the July 30 final pretrial conference. Instead, days before trial (and well after the July 15 motion in limine deadline), An- drews moved to exclude, under Federal Rule of Evid