Diaz v. United States
602 U.S. 526
SCOTUS2024Background
- Delilah Diaz was stopped at the U.S.-Mexico border, where border officers found over 54 pounds of methamphetamine concealed in her car.
- Diaz was charged with importing methamphetamine, a crime requiring proof that she "knowingly" transported the drugs.
- Diaz asserted a "blind mule" defense, claiming she did not know drugs were hidden in her vehicle.
- The government called Agent Flood as an expert to testify that most drug couriers know they are transporting drugs; Diaz objected, citing Federal Rule of Evidence 704(b).
- The district court allowed Agent Flood to testify that "most" couriers know, but not that all do; Diaz was convicted and appealed.
- The Ninth Circuit upheld Diaz’s conviction, and the Supreme Court granted certiorari on the Rule 704(b) issue.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether expert testimony that "most couriers know" | Flood’s testimony is functionally about Diaz’s mental state | Testimony concerns a group, not Diaz specifically | Testimony about “most” is not about Diaz specifically; not a Rule 704(b) violation |
| violates Federal Rule of Evidence 704(b) | and therefore violates Rule 704(b). | and leaves decision to jury. |
Key Cases Cited
- United States v. Spaulding, 293 U.S. 498 (1935) (discussing the common law ultimate-issue rule that expert witnesses could not state conclusions on issues the jury must decide)
- Miranda v. Arizona, 384 U.S. 436 (1966) (providing context for Diaz’s post-arrest statements)
- Morissette v. United States, 342 U.S. 246 (1952) (discussing the importance of mens rea in criminal law)
- Francis v. Franklin, 471 U.S. 307 (1985) (holding burden of proof for state of mind must remain with the government)
- Daubert v. Merrell Dow Pharmaceuticals, Inc., 509 U.S. 579 (1993) (establishing standards for admissibility of expert testimony)
- Kumho Tire Co. v. Carmichael, 526 U.S. 137 (1999) (reaffirming trial court's gatekeeping role for expert testimony)
