United States v. Leroy Goree, 756 F.3d 522

Goree was convicted by a jury of conspiring to possess with intent to distribute less than 28 grams of crack cocaine in violation of 21 U.S.C. §§ 841(a)(1) and 846.
Prosecution showed Goree and Woods traveled to Chicago to purchase crack cocaine from Hicks via Gavin, with Gavin acting as broker.
Two drug transactions occurred: April 29, 2008 (about 9 ounces) and May 6, 2008 (about a half kilogram) at Garfield Gyros parking lot.
Masuca delivered cocaine to Gavin; goods and proceeds were exchanged through Woods and Goree, with surveillance and wiretap evidence supporting the deals.
Goree admitted during later interviews that he traveled to Chicago to purchase crack cocaine and helped with security during the deals; he disposed of drugs to avoid arrest.
Goree moved for a directed verdict and later for judgment of acquittal, which the district court denied; the jury affirmed the conspiracy conviction.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Was there a conspiracy agreement beyond mere presence?	Goree's presence and aid were insufficient to prove agreement.	Goree did not actively participate or profit, so no conspiracy.	Yes; substantial evidence supports a single agreement.
Did Goree knowingly and willfully participate in the conspiracy?	Goree admitted traveling to Chicago to purchase crack cocaine and aided the deals.	Participation was limited to security, not the deals or profits.	Yes; Goree knowingly participated and aided the conspiracy.
Is the standard of review appropriate to sustain the conviction?	Evidence viewed in the government’s favor supports the verdict.	The evidence might be insufficient for reasonable doubt.	The standard of review supports affirmance; rational jury could find guilt beyond reasonable doubt.

United States v. Burrell, 963 F.2d 976 (7th Cir. 1992) (presence at a drug deal with active involvement may support conspiracy)
United States v. Love, 706 F.3d 832 (7th Cir. 2013) (sufficiency review for conspiracy upheld under proper standard)
United States v. Jenkins, 419 F.3d 614 (7th Cir. 2005) (sufficiency review framework for conspiracy)
United States v. Pazos, 993 F.2d 136 (7th Cir. 1993) (need for substantial evidence of conspiracy and knowing participation)
United States v. Townsend, 924 F.2d 1385 (7th Cir. 1991) (circumstantial evidence can support conspiracy verdict if inference of agreement reasonable)
United States v. Hunte, 196 F.3d 687 (7th Cir. 1999) (participation without profit motive can still sustain conspiracy)
United States v. Sasson, 62 F.3d 874 (7th Cir. 1995) (active participant with involvement in multiple deals can sustain conspiracy)
United States v. Auerbach, 913 F.2d 407 (7th Cir. 1990) (definition of substantial evidence in conspiracy cases)
United States v. Ramirez, 45 F.3d 1096 (7th Cir. 1995) (defendant provided transportation or other support can sustain conspiracy)
United States v. Gregory, 74 F.3d 819 (7th Cir. 1996) (security role during drug transactions supports conspiracy conviction)
United States v. Vega, 72 F.3d 507 (7th Cir. 1995) (presence and handling of cocaine can support conspiracy conviction)
United States v. Carrillo, 435 F.3d 767 (7th Cir. 2005) (circumstantial evidence can prove conspiracy if inference of agreement is reasonable)