United States v. Araiza-Jacobo, 917 F.3d 360

Araiza-Jacobo, a lawful permanent resident and regular "cruzador," crossed the U.S.–Mexico Gateway Bridge carrying two bags labeled as candy; agents discovered >5.1 kg of ~98% methamphetamine concealed in the candy.
Border agents observed anomalies (weight, texture, mismatched candies, missing lollipop sticks), used a canine and field test that indicated meth, and placed Araiza-Jacobo under arrest.
During custodial interviews Araiza-Jacobo waived Miranda rights but gave multiple inconsistent stories about how he obtained the bags and his contacts with an unknown supplier; phone records showed repeated calls with that supplier.
Government charged him with possession with intent to distribute, conspiracy, and importation offenses, all requiring proof of knowing and intentional conduct.
At trial the district court instructed the jury it could infer knowledge from "deliberate ignorance" (deliberately closing one’s eyes), over defense objection; jury convicted on all counts.
On appeal the Fifth Circuit reviewed the instruction for abuse of discretion, concluded the deliberate-ignorance instruction was erroneous but harmless because substantial evidence supported actual knowledge, and affirmed the conviction.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether a deliberate-ignorance jury instruction was appropriate	Gov: Evidence showed Araiza-Jacobo was subjectively aware of a high probability of illegal conduct and thus instruction warranted	Araiza-Jacobo: No evidence he purposely contrived to avoid learning; instruction risks diluting mens rea	Court: Instruction was erroneous because no evidence of purposeful contrivance to avoid learning
Whether error was harmless	Gov: Even if instruction error, substantial evidence shows actual knowledge so conviction stands	Araiza-Jacobo: Instruction was reversible error affecting verdict	Court: Error harmless; substantial circumstantial evidence supported actual knowledge
Sufficiency of evidence for knowledge	Gov: Inconsistent statements, phone records, attempts to distract agents, large drug quantity show knowledge	Araiza-Jacobo: Claimed he thought bags contained candy and trusted the supplier	Court: Credibility issues, quantity, evasive behavior, and misdirections supported actual knowledge
Standard for giving deliberate-ignorance instruction	Gov: Routine application when suspicious facts present	Araiza-Jacobo: Instruction should be rare and only when purposeful avoidance shown	Court: Reiterated instruction should rarely be given; requires subjective awareness and purposeful contrivance; here second prong lacking

United States v. Oti, 872 F.3d 678 (5th Cir. 2017) (cautioning against use of deliberate-ignorance instruction)
United States v. Nguyen, 493 F.3d 613 (5th Cir. 2007) (deliberate-ignorance test: subjective awareness and purposeful contrivance)
United States v. Lara-Velasquez, 919 F.2d 946 (5th Cir. 1990) (evidence supporting actual knowledge often overlaps with deliberate-ignorance inference)
United States v. Mendoza-Medina, 346 F.3d 121 (5th Cir. 2003) (warning against routine use of instruction)
United States v. Peterson, 244 F.3d 385 (5th Cir. 2001) (purposeful contrivance requirement)
United States v. St. Junius, 739 F.3d 193 (5th Cir. 2013) (review is fact-intensive; harmless-error precedent)
United States v. Casilla, 20 F.3d 600 (5th Cir. 1994) (inconsistent statements can support knowledge)
United States v. Lopez-Monzon, 850 F.3d 202 (5th Cir. 2017) (high drug quantity/value probative of knowledge)
United States v. Garcia-Flores, 246 F.3d 451 (5th Cir. 2001) (large quantity of drugs circumstantial evidence of knowledge)
United States v. Wofford, 560 F.3d 341 (5th Cir. 2009) (evidence supporting subjective awareness also supports actual knowledge)