United States v. Craig Claxton, 57 V.I. 821

Claxton was convicted by a jury of conspiring to possess cocaine with intent to distribute, but the district court acquitted him for lack of knowledge of drugs; government appeals and we reverse and remand for sentencing.
Springette ran a large drug-trafficking organization moving cocaine from Colombia to Venezuela and then to the Virgin Islands for distribution in the continental U.S.
Isaac identified Claxton as a member of the organization who helped move money by coordinating couriers; Claxton interacted with multiple couriers.
Three couriers—Alexis Wright, Valencia Roberts, and Demeatra Cox—testified that Claxton met them in St. Thomas, helped with their luggage, and was involved in money-related tasks.
Isaac testified to ten or more trips to St. Thomas, meetings at a farm where cocaine was stored, and discussions of drug activity; the farm functioned as a hub for the organization.
The district court reserved judgment on Claxton’s Rule 29 motion; the jury verdict prompted renewed post-trial motions and the district court ultimately entered an acquittal that the government challenges on appeal.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the evidence suffices to prove Claxton knowingly participated in the drug conspiracy.	Government argues Claxton knowingly joined the drug enterprise.	Claxton contends no evidence shows knowledge of drugs as the conspiracy’s object.	Yes; evidence supports knowing participation.
Whether circumstantial and coconspirator testimony can establish knowledge in a drug conspiracy case.	Government relies on coconspirator identifications and role in money transport.	Claxton argues lack of direct evidence linking him to drugs and object of conspiracy.	Circumstantial evidence, including coconspirator testimony, can establish knowledge.
Whether the district court erred in granting a judgment of acquittal on sufficiency grounds.	Government contends evidence viewed in the light most favorable supports guilt.	Claxton argues there is insufficient evidence for knowing participation.	District court’s acquittal reversed; evidence sufficient to support conviction.

United States v. Boria, 592 F.3d 476 (3d Cir. 2010) (knowledge in drug conspiracy can be inferred from circumstantial facts when an additional piece of evidence imputes knowledge of drugs)
United States v. Cartwright, 359 F.3d 281 (3d Cir. 2004) (circumstantial evidence must have logical connection to proven fact; not all suspicious conduct proves knowledge)
United States v. Wexler, 838 F.2d 88 (3d Cir. 1988) (conspiracy may be proven by circumstantial evidence; lookouts alone may be insufficient)
United States v. Idowu, 157 F.3d 265 (3d Cir. 1998) (presence and relationship alone may be insufficient to prove knowledge of objects of conspiracy)
United States v. Reyeros, 537 F.3d 270 (3d Cir. 2008) (direct knowledge evidence can bolster circumstantial inferences about conspiracy object)
United States v. Iafelice, 978 F.2d 92 (3d Cir. 1992) (knowledge can be proven grain-by-grain by circumstantial evidence)
United States v. Cooper, 567 F.2d 252 (3d Cir. 1977) (insufficient evidence where defendant lacked dominion over contraband; role must imply control)
United States v. Thomas, 114 F.3d 403 (3d Cir. 1997) (dominion/control over contraband must be inherent to defendant’s role)
United States v. Brodie, 403 F.3d 123 (3d Cir. 2005) (review sufficiency by considering the record as a whole)