A recent unpublished opinion from the Fourth Circuit explores the issue of "code words" and "drug slang." The issue with these "codes" is whether a lay witness can explain to the jury what they mean, or only an expert. The trial court allowed the testimony, and because the defense did not object, the Fourth Circuit was using plain error standard. The court held that there was no controlling precedent from this circuit or the Supreme Court, so no plain error. But it is an issue that will likely rise again.