United States v. Daniels
21-50024
| 5th Cir. | Oct 4, 2021Background
- Ashley Nicole Daniels and Ronnie Lee Hightower were tried and convicted by a jury for conspiracy to possess with intent to distribute five grams or more of actual methamphetamine.
- A confidential informant reported Daniels and Hightower were selling meth from their fifth-wheel trailer; a controlled buy was conducted with both present and actively participating; the transaction was recorded and surveilled.
- During the buy Daniels and Hightower discussed prior meth purchases, suggesting larger-scale trafficking activity.
- Law enforcement searched the trailer two days later and found nearly an ounce of methamphetamine, baggies, digital scales, and a floor safe; a narcotics expert testified these items were consistent with trafficking.
- Defendants argued the evidence was insufficient to support the conspiracy conviction and Daniels challenged the reliability of the audio and a detective’s voice identification.
- The district court conviction was appealed; because the defendants preserved sufficiency challenges, the Fifth Circuit reviewed those claims de novo.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Sufficiency of evidence for conspiracy to possess with intent to distribute ≥5 g meth | Gov't: recorded buy, surveillance, trafficking indicia, and recovered meth support a reasonable inference of an agreement and participation | Daniels/Hightower: evidence insufficient to prove conspiracy beyond a reasonable doubt | Affirmed — evidence sufficient under Jackson standard when viewed in gov't’s favor |
| Possession/control of trailer and floor safe where drugs found | Gov't: defendants had exclusive control/custody of trailer; items recovered there link them to the drugs | Daniels/Hightower: lack of direct proof of exclusive control undermines possession inference | Affirmed — jury could reasonably infer constructive possession from circumstantial evidence |
| Reliability of voice identification from recording | Gov't: Detective had sufficient familiarity with Daniels’ voice to identify her; jury decides weight | Daniels: recording is hard to hear and ID is unreliable | Affirmed — testimony showed “some familiarity”; jury decides credibility |
Key Cases Cited
- United States v. Carbins, 882 F.3d 557 (5th Cir. 2018) (de novo review for preserved sufficiency challenges)
- United States v. Vargas-Ocampo, 747 F.3d 299 (5th Cir. 2014) (Jackson standard for sufficiency of the evidence)
- Jackson v. Virginia, 443 U.S. 307 (1979) (sufficiency review: whether any rational trier of fact could find guilt beyond a reasonable doubt)
- United States v. Mitchell, 484 F.3d 762 (5th Cir. 2007) (elements required to convict for conspiracy to possess with intent to distribute)
- United States v. Zamora-Salazar, 860 F.3d 826 (5th Cir. 2017) (jury may infer conspiracy elements from circumstantial evidence)
- United States v. Jones, 873 F.3d 482 (5th Cir. 2017) (voice-identification admissibility may rest on witness familiarity)
- United States v. Cuesta, 597 F.2d 903 (5th Cir. 1979) (jury determines weight and credibility of identification testimony)