On April 22, 2023, Maxfer Palma was arrested with a man named Keith Tyler-Parker. Tyler-Parker was holding a backpack and satchel that contained drugs, including methamphetamine and fentanyl, drug paraphernalia, and a gun. He made statements to police that supposedly connected Palma to the bags.
The government intended to call Special Agent Hakeem Oduniyi to testify regarding methamphetamine and fentanyl distribution, and the possession and use of firearms by narcotics traffickers. Defendant Maxfer Palma filed a motion to exclude certain of Oduniyi’s expert opinions as irrelevant.
Narcotics Expert Witness
Special Agent Hakeem Oduniyi received formal training at the DEA Basic Agent training Academy in Quantico, Virginia. The 14-week Basic Agent Academy included comprehensive, formalized instruction in, among other things: drug investigations, drug identification and detection, interdiction, familiarization with United States drug laws, financial investigations and money laundering, identification and seizure of drug-related assets, organized crime investigations, physical and electronic surveillance, and undercover operations.
Oduniyi has participated in ongoing education, including a 50-hour undercover drug enforcement techniques course and 16-hour money service business: roundtable training. He has also served as a panelist at a fentanyl symposium.
Discussion by the Court
The Court excluded Oduniyi’s opinion on the practice of “cutting” drugs by mixing or diluting them with other substances.
However, testimony that narcotics are often diluted before sale helps explain why the drugs in this case are not 100 percent pure. Testimony that fentanyl is dangerous in small doses supports the government’s allegation that the quantity possessed by Defendant would not have been possessed for personal use. There is no undue prejudice to the Defendant from admission of these opinions offered by Oduniyi.
Held
The Court granted in part and denied in part Palma’s motion to exclude certain opinions of Hakeem Oduniyi.
Key Takeaway
Oduniyi’s testimony has sufficient probative value in explaining the general process of drug distribution.
Case Details:
| Case Caption: | United States V. Palma |
| Docket Number: | 4:23cr187 |
| Court Name: | United States District Court, California Northern |
| Order Date: | February 15, 2026 |
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