The following excerpt is from United States v. Gadson, 763 F.3d 1189 (9th Cir. 2014):
4. The majority opinion references six other circuits, which it says allow officers to provide interpretations of recorded conversations based on their knowledge of the investigation, subject to various safeguards. See Maj. Op. at 1207 n. 5. A careful review of the cases cited makes clear that they do not condone what happened here. See, e.g., United States v. Albertelli, 687 F.3d 439, 44448 (1st Cir.2012) (approving officer's testimony where it did not rely on broad appeals to the totality of the investigation but instead usually pointed to sources of information); United States v. Jayyousi, 657 F.3d 1085, 110203 (11th Cir.2011) (approving police officer's testimony regarding the meaning of code words used in recorded telephone calls); United States v. Rollins, 544 F.3d 820, 83033 (7th Cir.2008) (same).
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