United States v. Karen Collins, 20-10046

Background

Karen Collins appealed her conviction for conspiracy to import five kilograms or more of cocaine (21 U.S.C. §§ 963, 952, 960), asserting evidentiary and sufficiency errors; the Eleventh Circuit affirmed.
The government introduced Collins’s 2001 conviction for sale/delivery of cannabis under Fed. R. Evid. 404(b) to prove intent/knowledge; Collins argued it was remote, dissimilar, and unduly prejudicial.
Trial evidence included testimony from multiple women Collins recruited or helped (Sands, Jenkins, Carls, Conway, Moore, Nguyen), showing she arranged trips, paid for passports/tickets, and offered payment for transporting/returning bags.
On one trip coordinated by Collins and codefendants, 2.5 kilograms of cocaine were seized from returning travelers; other corroboration included phone/calendar entries and bank records showing travel purchases and same-day cash transactions.
The district court gave a limiting instruction on the 2001 conviction’s use (intent/knowledge only); the conviction was introduced at the close of the government’s case and not emphasized in closing.
The Eleventh Circuit held any error in admitting the 2001 conviction was harmless and that the evidence was sufficient to support the jury’s finding that Collins knowingly joined and participated in the conspiracy.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Admission of 2001 conviction under Rule 404(b)	Collins: prior cannabis conviction was remote/dissimilar and overly prejudicial; probative value was substantially outweighed by prejudice	Gov.: prior drug offense relevant to Collins’s intent/knowledge; admissible under Rule 404(b); limiting instruction mitigates prejudice	Even if admission was erroneous, error was harmless given strong untainted evidence, corroboration, and limiting instruction; conviction affirmed
Sufficiency of the evidence (motion for judgment of acquittal)	Collins: insufficient proof she willfully and knowingly entered the conspiracy to import ≥5 kg cocaine	Gov.: witness testimony and documentary evidence show Collins recruited travelers, paid for passports/tickets, coordinated trips, and knew/benefited from drug transport	Denial of acquittal affirmed — a reasonable jury could find Collins knowingly and voluntarily participated in the conspiracy

Key Cases Cited

United States v. Brown, 587 F.3d 1082 (11th Cir. 2009) (standard of review for Rule 404(b) evidentiary rulings)
United States v. Langford, 647 F.3d 1309 (11th Cir. 2011) (harmless-error standard for evidentiary rulings)
United States v. Barron-Soto, 820 F.3d 409 (11th Cir. 2016) (prior drug dealings probative of intent to distribute and conspiracy involvement)
United States v. Matthews, 431 F.3d 1296 (11th Cir. 2005) (not-guilty plea makes intent a material issue; Rule 404(b) evidence may be used to prove intent)
United States v. Jernigan, 341 F.3d 1273 (11th Cir. 2003) (factors for Rule 403 balancing: prosecutorial need, similarity, temporal remoteness)
United States v. Lampley, 68 F.3d 1296 (11th Cir. 1995) (admission of older, small-scale marijuana offenses upheld despite differences from charged large cocaine offense)
United States v. Sanders, 668 F.3d 1298 (11th Cir. 2012) (temporal remoteness can render prior conviction inadmissible, though error may be harmless)
United States v. Hands, 184 F.3d 1322 (11th Cir. 1999) (context of trial and government argument considered in harmless-error analysis)
United States v. Edouard, 485 F.3d 1324 (11th Cir. 2007) (limiting instruction mitigates unfair prejudice from admission of prior conduct)
United States v. Arbane, 446 F.3d 1223 (11th Cir. 2006) (elements for conspiracy to import and requirement that defendant knowingly participated)
United States v. Miranda, 425 F.3d 953 (11th Cir. 2005) (government need not prove knowledge of all conspiracy details; circumstantial evidence may suffice)
United States v. Klopf, 423 F.3d 1228 (11th Cir. 2005) (circumstantial evidence must support reasonable inferences, not mere speculation)