United States v. Araceli Garcia, 883 F.3d 570

On May 13, 2016, a Cadillac Escalade from Mexico entered the Laredo port of entry; Araceli Garcia (vehicle owner) rode as a passenger while her 17‑year‑old daughter drove and five–six children occupied the vehicle.
CBP officers discovered two children using false Texas birth certificates; further investigation revealed the children were Mexican nationals (D.I.P.M. and M.G.M.) without authorization to enter the U.S.
D.I.P.M. testified she had met Garcia in Nuevo Laredo the day of the crossing; Garcia provided the false identities and paperwork and was the person designated to smuggle the children into the U.S.
D.I.P.M. testified that Garcia was to be paid ‘‘expenses’’ for the journey, but she did not know the amount or whether additional payment was promised.
A grand jury indicted Garcia on two counts under 8 U.S.C. § 1324(a)(2)(B)(ii) (bringing unlawful aliens into the U.S. for the purpose of commercial advantage or private financial gain); a jury convicted her on both counts and the district court imposed concurrent three‑year terms (statutory minimum).
On appeal Garcia challenged only the sufficiency of the evidence that she acted for commercial advantage or private financial gain.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether evidence proved Garcia acted "for the purpose of commercial advantage or private financial gain" under 8 U.S.C. § 1324(a)(2)(B)(ii)	The Government argued the totality of circumstantial evidence (D.I.P.M.'s testimony about expenses, planning, false IDs, unfamiliarity with the children, and a financier) supported an inference of a pecuniary motive.	Garcia argued the only monetary proof was an expected reimbursement for expenses, which does not constitute financial gain under the statute, so evidence was insufficient.	The court adopted a pecuniary‑benefit definition (profit or economic improvement beyond mere reimbursement) and held the circumstantial evidence was sufficient to allow a rational jury to infer a financial purpose; conviction affirmed.

United States v. Vargas‑Ocampo, 747 F.3d 299 (5th Cir.) (standard for sufficiency review under Jackson v. Virginia)
Jackson v. Virginia, 443 U.S. 307 (1979) (standard for reviewing sufficiency of the evidence)
United States v. Zheng, 306 F.3d 1080 (11th Cir.) (defining "commercial advantage" and "private financial gain" as pecuniary benefit)
United States v. Fujii, 301 F.3d 535 (7th Cir.) (pecuniary motive can include satisfying a pre‑existing debt)
United States v. Bailey, 444 U.S. 394 (1980) (purpose corresponds to specific intent)
United States v. Giraldi, 86 F.3d 1368 (5th Cir.) (mental state usually proven circumstantially)
United States v. Kim, 435 F.3d 182 (2d Cir.) (no actual payment or agreement to pay required to infer financial purpose)
United States v. Angwin, 271 F.3d 786 (9th Cir.) (similar on inferring financial intent without explicit payment)
United States v. Chapman, 851 F.3d 363 (5th Cir.) (inferring intent from circumstantial indicators in drug cases)
United States v. Williamson, 533 F.3d 269 (5th Cir.) (possession quantity as circumstantial proof of intent)
United States v. Munoz, 957 F.2d 171 (5th Cir.) (distribution paraphernalia and cash probative of intent)
United States v. Yoshida, 303 F.3d 1145 (9th Cir.) (transporting strangers supports inference of expected payment)
United States v. Garza, 587 F.3d 304 (5th Cir.) (contrast where record established lack of financial motive)