State v. Matthew Steven Taylor, 335 P.3d 31

Taylor was convicted by a jury of conspiracy to manufacture, deliver or possess with intent to deliver a controlled substance; conspiracy to deliver or possess with intent to deliver drug paraphernalia; and delivery of a controlled substance.
Evidence tied Taylor to a Red Eye Hut head shop operation selling Twizted Potpourri containing synthetic cannabinoids (JWH-019, AM-2201) and to a warehouse with manufacturing components for synthetic cannabinoids.
Investigators observed Taylor at the Red Eye Hut and purchased three containers from him; searches seized thousands of containers and drug paraphernalia.
Taylor argued he did not know Twizted Potpourri contained a controlled substance; district court denied acquittal on the delivery and conspiracy charges but granted a new trial on the conspiracy counts for misinstruction defense.
The district court instructed that mistake of law is not a defense to the delivery charge and that conspiracy required an agreement and intent to commit a crime, but later granted a new trial on conspiracy charges.
This Court affirmed denial of acquittal and denial of a new trial on the delivery charge, but reversed the grant of a new trial on the conspiracy charges.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Sufficiency of evidence for delivery/conspiracy	Taylor argues insufficient evidence to convict on delivery and conspiracy.	Taylor contends lack of knowledge that Twizted Potpourri contained a controlled substance prevents conspiracy and delivery guilt.	Sufficiency upheld for delivery; conspiracy reversal issued on defense doctrine.
New trial on the delivery charge	State argues no instructional error; proper jury instructions existed.	Taylor claims instructions misled the jury about knowledge and defense theories.	No reversible error; instructions correctly required knowledge or belief that a synthetic cannabinoid was a controlled substance.
New trial on the conspiracy charges	State argues no mistake-of-law defense in conspiracy statutes; trial court properly denied new trial for conspiracy charges.	Taylor asserts mistake-of-law defense should apply to conspiracy, due to lack of knowledge that potpourri was illegal.	Reversed district court; no mistake-of-law defense under conspiracy statutes; conspiracy charges warranted new trial reversal.

State v. Alley, 155 Idaho 972 (2014) (AM-2201 pretrial dismissal and conspiracy knowledge issues related to Schedule I substances)
State v. Adamcik, 272 P.3d 417 (Idaho 2012) (sufficiency review; Jackson v. Virginia standard for judging evidence)
State v. Cantu, 931 P.2d 1191 (Idaho 1997) (abuse of discretion standard for granting new trials; three-tier test)