Whether law enforcement agent testimony under Federal Rule of Evidence 701 based on overall investigation knowledge is permissible

QUESTION PRESENTED FOR REVIEW May a law enforcement agent give lay opinion testimony under Federal Rule of Evidence 701 based on the agent’s overall knowledge of an investigation, as maintained by several circuit courts of appeals, or does such testimony run afoul of the Rule’s foundation requirement that such testimony be rationally based on the perception of the witness, as maintained by several other circuit courts of appeals? i STATEMENT OF RELATED CASES * United States of America v. Rodrigo Alvarez-Quinonez, No. U.S. District Court for Western Washington. Judgment entered September 16, 2022. * United States of America v. Rodrigo Alvarez-Quinonez, No. 22-30161, U.S. Court of Appeals for the Ninth Circuit. Judgment entered December 4, 2023. ii