United States v. Alvin Gaskins, 402 U.S. App. D.C. 262

Gaskins was convicted as a member of a narcotics conspiracy operating from 1999 to 2004 across Virginia, D.C., and Maryland.
Government evidence included eight cooperating witnesses, 14,000+ intercepted calls, surveillance, and searches, but none linked Gaskins to drugs or drug transactions.
Cooperating witnesses testified about others’ activities; none stated Gaskins knew of drug trafficking.
Gaskins’ defense claimed he was a gofer for Dream Team Investigations (DTI) and not part of a drug conspiracy.
Jury initially found not proven on narcotics conspiracy objects; later verdicts shifted to guilty, leading to judgment and sentence.
This court reversed, ruling no reasonable jury could find Gaskins knowingly joined the conspiracy with the specific intent to distribute narcotics.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Was there sufficient evidence Gaskins knowingly joined with specific intent?	Gaskins engaged in activities indicating knowledge and intent.	No evidence he knew of or intended to further drug distribution.	No; evidence insufficient to prove specific intent beyond reasonable doubt.
Can lease, cell-phone, or other peripheral ties establish knowing participation?	Lease and phone imply involvement in conspiracy.	Handwriting, ownership, and access were not proven; no knowledge of drug activity.	No; these factors do not prove knowing participation with required intent.
May flight bookings for a conspirator be used to infer participation?	Airline bookings tied to conspirator’s finances show involvement.	No evidence Gaskins knew the trips’ purpose related to drugs.	No; lack of knowledge about purpose defeats inference of intent.
Does close association with Miller amount to conspiracy participation?	Frequent interactions show involvement in the enterprise.	Association alone is insufficient to prove participation with specific intent.	No; mere association or related conversations do not prove knowing participation.
Are the government’s broad comparisons to other cases controlling here?	Other cases show same types of circumstantial evidence establish conspiracy.	Those cases involved stronger links; the current record lacks direct ties to drugs.	No; the record here is weaker than cited precedents; conviction reversed.

Ingram v. United States, 360 U.S. 672 (1959) (conspiracy requires the intent necessary for the substantive offense)
United States v. Wilson, 160 F.3d 732 (D.C. Cir. 1998) (need specific intent to further conspiracy objective)
United States v. Tarantino, 846 F.2d 1384 (D.C. Cir. 1988) (conspiracy requires knowledge and intent to promote unlawful end)
United States v. Childress, 58 F.3d 693 (D.C. Cir. 1995) (knowledge plus specific intent required for narcotics conspiracy)
United States v. Viola, 35 F.3d 37 (2d Cir. 1994) (absence of evidence linking Formisano to the conspiracy defeats conviction)
United States v. Brown, 560 F.3d 754 (8th Cir. 2009) (facts show stronger ties to drug activity than here; mere proximity insufficient)