United States v. Denson, 2012 U.S. App. LEXIS 16027

Todd Denson was convicted in federal court of multiple wire-fraud counts related to a Nigerian scam that victimized others and involved misrepresentations about vast overseas funds.
After his initial prison term and while on supervised release, Denson again defrauded people by claims of overseas windfalls and forged documents to solicit money.
At sentencing, the district court imposed 30-month terms for the wire-fraud convictions (within the advisory range) and 15 months for supervised-release violations (above the range), ordering the sentences to run consecutively.
Denson appealed, challenging jury instructions (willful blindness and good-faith guidance) and the sentencing under 18 U.S.C. § 3553(a), including considerations of health issues.
The district court relied on Denson’s health condition—pure autonomic failure—to influence sentencing and argued public protection and deterrence were legitimate factors given his history.
The First Circuit affirmed, holding that the jury instructions were proper and that the sentences were procedurally sound and substantively reasonable under § 3553(a).

Issue	Plaintiff's Argument	Defendant's Argument	Held
Was the willful-blindness instruction legally correct?	Denson argued the instruction allowed a reasonable-person standard and confused intent.	Denson contended the instruction was misdirected and potentially incorrect.	Instruction aligned with governing law; no reversible error.
Was the good-faith instruction properly limited to Denson's subjective belief?	Denson claimed the instruction did not adequately reflect his subjective belief requirement.	The instruction effectively focused on Denson's beliefs.	No reversible error; instruction adequately tailored to Denson’s state of mind.
Did the sequencing of willful-blindness and good-faith instructions constitute plain error?	Sequencing might have misled the jury and constituted plain error.	No error in sequencing given the prior rulings and record.	No plain error; sequencing did not warrant reversal.
Are the challenged sentences under § 3553(a) reasonable given health, public protection, and history?	Health issues and overemphasis on public protection undermine reasonableness.	Judge adequately weighed health, deterrence, and history; sentences are reasonable.	Sentences are procedurally sound and substantively reasonable.

United States v. Jadlowe, 628 F.3d 1 (1st Cir. 2011) (standard for reviewing jury instruction adequacy)
United States v. De Jesús-Viera, 655 F.3d 52 (1st Cir. 2011) (willful blindness standard; required subjective belief)
United States v. Azubike, 564 F.3d 59 (1st Cir. 2009) (justification for willful-blindness instruction)
United States v. Gonzalez, 570 F.3d 16 (1st Cir. 2009) (willful blindness and knowledge inferences)
United States v. Griffin, 524 F.3d 71 (1st Cir. 2008) (defining willful blindness and focus on defendant)
United States v. Vargas-Dávila, 649 F.3d 129 (1st Cir. 2011) (considerations of health in sentencing)