United States v. Isabel Trejo
2016 U.S. App. LEXIS 14494
| 8th Cir. | 2016Background
- In 2013 law enforcement surveilled Isabel Mata Trejo’s rural property and observed men moving liquid in containers, digging, and packaging behavior consistent with methamphetamine processing and storage.
- A May 2013 search of the property uncovered ~5,050 grams of methamphetamine buried in Tupperware/bags, an operational conversion lab in the garage (hot plates, acetone, scales, strainers, vacuum sealer, packaging), and in Mata Trejo’s house $4,000 in small bills, a firearm, scales, and multiple cell phones.
- Officers observed Mata Trejo on the property near the garage and saw vehicles used in controlled buys in the area. Some recovered methamphetamine was dirt-encrusted in containers like those observed.
- Mata Trejo testified she was unaware of drug activity, claimed a man called “Camaro” stored a bag of clothes in the garage for $3,000, and asserted ownership of the money and firearm.
- A jury convicted Mata Trejo of conspiracy to distribute methamphetamine but acquitted her of possession with intent to distribute and possession of a firearm in furtherance of a drug trafficking crime. She moved for acquittal and objected to a deliberate-ignorance (willful blindness) jury instruction. The district court denied the motion and gave the instruction; the Eighth Circuit affirmed.
Issues
| Issue | Plaintiff's Argument (Mata Trejo) | Defendant's Argument (Government) | Held |
|---|---|---|---|
| Sufficiency of evidence for conspiracy under 21 U.S.C. § 846 | Verdict inconsistent: acquittal on possession means insufficient evidence for conspiracy | Different elements govern conspiracy vs possession; circumstantial and physical evidence supports conspiracy membership/knowledge | Affirmed — evidence sufficient to convict of conspiracy when viewed in government’s favor |
| Appropriateness of deliberate-ignorance (willful blindness) instruction | No basis for willful blindness; evidence supports only actual knowledge or no knowledge — instruction improper | Evidence supported inference of high probability of wrongdoing and deliberate avoidance (large payments for storage, money, scales, buried meth, activity on property) | Affirmed — instruction proper because jury could infer actual knowledge or deliberate ignorance |
Key Cases Cited
- United States v. Espinosa, 585 F.3d 418 (8th Cir. 2009) (standard of review for judgment of acquittal)
- United States v. Washington, 318 F.3d 845 (8th Cir. 2003) (sufficiency review; view evidence in light most favorable to government)
- United States v. Pizano, 421 F.3d 707 (8th Cir. 2005) (elements required to prove conspiracy)
- United States v. Galimah, 758 F.3d 928 (8th Cir. 2014) (willful blindness doctrine and instruction explained)
- Global-Tech Appliances, Inc. v. SEB S.A., 563 U.S. 754 (2011) (willful blindness principle in criminal and civil contexts)
- United States v. Chavez-Alvarez, 594 F.3d 1062 (8th Cir. 2010) (upholding willful blindness instruction where defendant chose not to investigate suspicious facts)