Jayyousi v. United States

Whether, consistent with the ruling below and that of four other circuits, and contrary to the rule in five circuits, lay opinion testimony satisfies Federal Rules of Evidence 701(a) and (b) -- which require that lay opinion testimony be "rationally based on the witness"s perception" and that it be "helpful" to the factfinder"s determination -- where the witness has no first-hand knowledge of the underlying events about which the witness opines.