United States v. Harris
666 F.3d 905
| 5th Cir. | 2012Background
- Harris and Miller were charged with conspiracy to launder monetary instruments and multiple money-laundering counts; jury found them guilty and forfeiture was ordered.
- Evidence showed Harris obtained narcotics in California, shipped to East Texas, and Miller and others in East Texas transmitted payments back to Harris in California.
- Between 2007 and 2009, over $2 million moved from East Texas to California through cash deposits/withdrawals and MoneyGram, often under $10,000 to dodge reporting.
- In the forfeiture phase, the jury found $1.5 million in laundered funds and several vehicles and seized currency involved in the offense.
- The government framed the case as drug proceeds being laundered via deposits, withdrawals, and wire transfers, though no drug charges were filed.
- Harris and Miller challenged the sufficiency of the evidence to prove that the transactions involved proceeds of drug trafficking.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether transactions involved proceeds of unlawful activity | Harris and Miller relied on Gaytan/Dimeck logic that payments for drugs are not proceeds until sale completed. | Harris and Miller contend funds were not proceeds at the time of transactions and thus not money laundering. | Proceeds not proven; judgment reversed. |
Key Cases Cited
- United States v. Gaytan, 74 F.3d 545 (5th Cir. 1996) (proceeds become drug proceeds only after the sale is completed; money laundering requires proceeds of unlawful activity)
- United States v. Dimeck, 24 F.3d 1239 (10th Cir. 1994) (mere delivery of drug-money by courier is not money laundering; focuses on timing of proceeds)
- United States v. Puig-Infante, 19 F.3d 929 (5th Cir. 1994) (money did not become proceeds until sale completed; transportation of cash not a financial transaction)
- United States v. Edgmon, 952 F.2d 1206 (10th Cir. 1991) (money laundering punishes proceeds after unlawful activity; timing matters)
- United States v. Penaloza-Duarte, 473 F.3d 575 (5th Cir. 2006) (standard for reviewing sufficiency of evidence on appeal)