Eleventh Circuit Court of Appeals - Published Opinions

Monday, July 10, 2017

Louis: Drug-Trafficking Convictions Reversed for Insufficient Evidence

In United States v. Louis, No. 16-11349 (July 10, 2017) (Wilson, Tjoflat, Robreno), the Court reversed a defendant's drug-trafficking convictions for insufficient evidence.

The Court emphasized that, in order to find the defendant guilty of conspiracy to posses cocaine with intent to distribute, and possession of cocaine with intent to distribute, the government was respectively required to prove beyond a reasonable doubt that the defendant knew the object of the conspiracy and that he was in possession of cocaine.  The Court found that, while there was sufficient evidence that the defendant knew that the boxes in question contained contraband that was illegal under some law, there was insufficient evidence to establish his knowledge that the boxes contained drugs.  The government relied heavily on the defendant's presence and flight, but the Court found this evidence, without more, to be insufficient.  The Court also rejected the government's reliance on an entrustment theory because, despite the large quantity of drugs, the defendant was present with the drugs only briefly and was never left alone with them.