United States v. Jabar Evans

── United States v. Jabar Evans ── Court: Court of Appeals for the Third Circuit Date: May 19, 2026 Category: General U.S. COURT OF APPEALS FOR THE THIRD CIRCUIT No. 24-2156 UNITED STATES OF AMERICA v. JABAR EVANS, also known as JB, also known as Hood, Appellant _____________________________ Appeal from U. S. District Court, D.N.J. Judge William J. Martini, No. 2:21-cr-00899-001 Before: RESTREPO, MCKEE AND AMBRO, Circuit Judges Argued Nov. 10, 2025; Decided May 19, 2026 _____________________________ OPINION OF THE COURT RESTREPO, CIRCUIT JUDGE Jabar Evans appeals his convictions for drug and firearm offenses that followed a search of his hotel room pursuant to a warrant. He alleges three trial court errors on appeal, none of which warrant relief. His claim that the District Court erred by admitting improper lay opinion testimony has merit, but any error was harmless in light of the evidence. For the following reasons, we will affirm the judgments of sentence. I. A. Facts On April 23, 2021, Evans checked into Room 306 of the Haiban Inn Hotel in Jersey City, New Jersey. Two months later, on June 21, 2021, Evans asked the hotel manager for a larger room and was given Room 207. That night, Evans and his friends moved his belongings into the larger room. Evans returned the keys for Room 306 to the hotel manager the next morning. The hotel’s housekeeping staff cleaned Room 306 later that day. A plastic bag containing two handguns and some letters with distinctive handwriting was found inside the room’s open safe. A housekeeper brought the bag to the hotel manager, who then called the police to report the guns. Patrol officers responded and collected the guns—a .45 handgun loaded with hollow point bullets and a 9 mm handgun with a defaced serial number and a missing magazine. The manager gave the officers a copy of Evans’ driver’s license and told them that Evans was there in his new hotel room. From Evans’ identification, police determined that there was an outstanding warrant for his arrest. On the night of June 22, 2021, officers from the Jersey City Police Department’s Emergency Services Unit (ESU) assembled outside the door of Room 207. Evans initially responded to an officer announcing their presence but became silent after they identified themselves as police. While the officers were attempting to persuade Evans to come to the door, Evans leaned out of the window and made eye contact with the officer positioned outside. After forty minutes of no response from Evans, the officers forced entry into the room. They found Evans on his bed and arrested him without incident. 2 Because Evans was recovering from a prior gunshot wound, the officers took him to the hospital for treatment. Meanwhile, Jersey City detectives obtained a warrant to search Room 207 for further evidence of weapons offenses, such as the missing magazine from the confiscated gun or “identifiers” that would link any firearms or firearm accessories to the resident of the room. Appx. 3. The warrant was executed in the early morning hours of June 23, 2021. Upon entering the room, the officers immediately found a small shoebox filled with bundled heroin. Nearby was a garbage bag filled with bundled heroin and boxes of empty glassine bags. Throughout the room were stamped glassine bags that contained controlled drug substances. Also recovered from the room were stamp pads and various stamps, as well as drug packaging materials covered in a white powdery residue: a mirror, scales, measuring cups, small scoops, a press, a grinder, a pestle, a strainer, and substances used to augment or “cut” different narcotics. During the search, a detective noticed a piece of tile from the room’s drop cei