March 01st, 2019

United States v. Araiza-Jacobo

Docket: 17-40958
Opinion Date: February 28, 2019
Judge: Stuart Kyle Duncan
Areas of Law: Criminal Law

Defendant was convicted of attempting to cross the United States border carrying two bags of hard candies impregnated with over 5.1 kilograms of methamphetamine. The Fifth Circuit held that the district court erred by instructing the jury that it could find defendant had culpable knowledge if he had been "deliberately ignorant" of the disguised drugs. The court stressed that a deliberate ignorance instruction should rarely be given. In this case, the instruction was not supported by evidence showing defendant engaged in purposeful contrivance to avoid learning of the illegal conduct. However, the court held that the error was harmless because substantial evidence supported the conclusion that defendant actually knew he was carrying illicit candy. Accordingly, the court affirmed the conviction.

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