United States v. Anderson, 747 F.3d 51

On April 16, 2011, law enforcement arrested Roohid Hakimi and cooperating witness Cheyenne Anderson after a K-9 alerted to a blue duffel bag in Anderson’s truck that contained ~20 pounds (≈30,000 pills) of ecstasy/related substances worth up to $900,000.
Anderson (a cooperating co-defendant) testified she had been directed by co-conspirators (Daisy Realza a/k/a “Perla,” and Dallas George) to meet a bald man in a blue-and-white sweater at the Massena Wal‑Mart to transfer the duffel for transport to New York City; that man was Hakimi.
Surveillance and testimony showed Hakimi followed Anderson from Wal‑Mart to a secluded dead‑end, sat in Anderson’s truck with the duffel at his feet, had multiple phone contacts with Realza and George in the days before the arrest, and gave a false statement to agents when stopped.
At trial a jury convicted Hakimi of (1) conspiracy to possess with intent to distribute controlled substances and (2) attempt to possess with intent to distribute; the district court granted a Rule 29 acquittal, concluding the evidence was insufficient to prove Hakimi’s knowledge and intent.
The Second Circuit, applying the Jackson sufficiency standard and deferring to reasonable inferences, reversed: it held a rational jury could infer Hakimi was a trusted participant who intended to receive and knew the bag contained illegal drugs, and therefore reinstated both convictions.

Issue	Government's Argument	Hakimi's Argument	Held
Sufficiency to sustain conspiracy conviction (knowledge/intent)	Evidence (Anderson’s testimony, phone records, conduct at meeting, solitary custody expectation for high‑value contraband) permits inference Hakimi knowingly joined conspiracy and knew the bag contained drugs	Hakimi was merely present or seeking to be smuggled into Canada; phone calls and presence are equivocal and do not show he knew the bag contained drugs	Reversed district court; jury verdict reinstated — a rational juror could infer Hakimi intended to take the bag, was trusted, and knew it contained illegal drugs
Sufficiency to sustain attempt conviction (intent + substantial step)	Hakimi took substantial steps (coordinating transfer, reaching meeting, following to secluded spot) and had the requisite intent as to the drugs	Without proof he knew the bag contained drugs, conduct is at most preparation; no direct evidence he handled or inspected contents	Reversed district court; jury verdict reinstated — conduct constituted a substantial step and the jury could infer intent

Jackson v. Virginia, 443 U.S. 307 (1979) (standard for reviewing sufficiency of evidence: uphold if any rational trier of fact could find guilt beyond reasonable doubt)
United States v. Huezo, 546 F.3d 174 (2d Cir. 2008) (permitting inference that principals would not entrust large value items to an outsider)
United States v. Torres, 604 F.3d 58 (2d Cir. 2010) (reversing where evidence was insufficient to show defendant knew packages contained drugs)
United States v. Nusraty, 867 F.2d 759 (2d Cir. 1989) (mere presence at an aborted transfer and mere association insufficient for conspiracy conviction)
United States v. Abelis, 146 F.3d 73 (2d Cir. 1998) (trusted position—sole control of valuable funds—may support inference of knowledge)