United States v. Heidi Haischer, 780 F.3d 1277

Heidi Haischer was indicted for wire fraud and conspiracy (2006–2007 mortgage loans) based on false loan applications and supporting documents; loans funded and later defaulted.
Her then‑boyfriend and co-worker, Kelly Nunes, prepared applications, obtained false employment verifications, and had access to her bank statements; Haischer testified she deferred to him.
Haischer alleged Nunes physically abused and coerced her (including a broken leg incident where she was forced to sign papers before treatment), and initially asserted a duress defense pretrial.
Midtrial defense counsel abandoned duress and pursued a mens rea defense (lack of knowledge/intent); after that change the district court excluded all evidence of the alleged abuse under Fed. R. Evid. 403 and told the jury to disregard any testimony of alleged abuse.
The court gave a "deliberate ignorance" (Jewell) instruction over Haischer’s objection; the jury convicted on both counts.
The Ninth Circuit held the complete exclusion of the abuse evidence was error that violated Haischer’s due process right to present a complete defense and vacated the convictions, remanding for further proceedings.

Issue	Haischer's Argument	Government's Argument	Held
Whether district court properly excluded all evidence of alleged abuse under Rule 403	Exclusion deprived her of central evidence to show lack of knowledge/intent and to rebut deliberate ignorance instruction	Evidence was unduly prejudicial and marginally probative after defense abandoned duress	Exclusion was erroneous; probative value was substantial and exclusion violated due process
Whether the Jewell (deliberate ignorance) instruction was proper without abuse evidence	Abuse evidence was necessary to show her failure to investigate was coerced, not deliberate	Instruction was supported by the record of misleading conduct and omissions	Instruction heightened prejudice because excluded abuse evidence was directly probative of whether ignorance was deliberate
Whether a defendant must admit mens rea before asserting duress	Haischer argued she could assert duress while denying requisite mens rea	Government suggested duress required admitting conduct/knowledge (district court misapprehension)	Court clarified duress can be asserted without conceding knowledge; inconsistent defenses permissible
Whether the evidentiary error was harmless beyond a reasonable doubt	Error rendered key defense evidence unavailable and could affect jury’s finding on mens rea	Government bears burden to show error harmless	Government failed to show harmlessness; convictions vacated and remanded

United States v. Jewell, 532 F.2d 697 (9th Cir.) (en banc) (establishing "deliberate ignorance" instruction)
United States v. Heredia, 483 F.3d 913 (9th Cir. 2007) (defining deliberate action and coercion’s effect on deliberate ignorance)
United States v. Pineda–Doval, 614 F.3d 1019 (9th Cir. 2010) (standard for when evidentiary error becomes constitutional)
United States v. Anderson, 741 F.3d 938 (9th Cir. 2013) (Rule 403 balancing description)
United States v. Yazzie, 59 F.3d 807 (9th Cir. 1995) (definition of unfair prejudice under Rule 403)
Hernandez v. Ashcroft, 345 F.3d 824 (9th Cir. 2003) (discussing patterns of coercive control in abusive relationships)
United States v. Evans, 728 F.3d 953 (9th Cir. 2013) (test for when exclusion of evidence violates due process)
United States v. Leal–Del Carmen, 697 F.3d 964 (9th Cir. 2012) (harmless‑beyond‑a‑reasonable‑doubt standard for constitutional errors)